Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The ITAT upheld the PCIT's exercise of revisionary jurisdiction under s.263, holding that s.263 is available to correct an order erroneous and prejudicial to the revenue even where the error is apparent from the record and potentially rectifiable under s.154 or s.147. The AO's order was found erroneous and prejudicial for disallowing depreciation on goodwill to the extent of Rs.10,89,82,058 as against the claim of Rs.27,63,20,888, and the PCIT's directions under s.263 were sustained. Merits of the depreciation claim (including reliance on judicial precedents) were left to the pending appeal against quantum before the ld. CIT(A). The assessee's appeal is dismissed.
The ITAT upheld the PCIT's exercise of revisionary jurisdiction under s.263, holding that s.263 is available to correct an order erroneous and prejudicial to the revenue even where the error is apparent from the record and potentially rectifiable under s.154 or s.147. The AO's order was found erroneous and prejudicial for disallowing depreciation on goodwill to the extent of Rs.10,89,82,058 as against the claim of Rs.27,63,20,888, and the PCIT's directions under s.263 were sustained. Merits of the depreciation claim (including reliance on judicial precedents) were left to the pending appeal against quantum before the ld. CIT(A). The assessee's appeal is dismissed.
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