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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The ITAT set aside the PCIT's revision under section 263, holding that the AO had conducted a detailed, reasoned inquiry-examining bank records, financial statements and other material-and took a legally permissible view regarding the loan quantum; the PCIT failed to make any independent enquiry sufficient to dislodge the AO's cogent findings. The Tribunal emphasized the distinction between absence of investigation and a mere difference of opinion, and held that revisionary powers cannot be exercised without recording specific failure and prejudice caused by the AO's proceedings. Consequently the PCIT's exercise of revisional jurisdiction was held to be unjustified and the AO's assessment order was restored.
The ITAT set aside the PCIT's revision under section 263, holding that the AO had conducted a detailed, reasoned inquiry-examining bank records, financial statements and other material-and took a legally permissible view regarding the loan quantum; the PCIT failed to make any independent enquiry sufficient to dislodge the AO's cogent findings. The Tribunal emphasized the distinction between absence of investigation and a mere difference of opinion, and held that revisionary powers cannot be exercised without recording specific failure and prejudice caused by the AO's proceedings. Consequently the PCIT's exercise of revisional jurisdiction was held to be unjustified and the AO's assessment order was restored.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
