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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ITAT allows the assessee's appeal and quashes the PCIT's revisional order, holding that the revisional jurisdiction was improperly invoked where the AO adopted a plausible view on taxability of interest under s.28 of the Land Acquisition Act and the issue remained debatable. The Tribunal finds the order under challenge prompted solely by an audit objection and therefore unsustainable. On the question of capital gains, ITAT holds the land qualifies as a capital asset within s.2(14) for the relevant year; the Finance Act amendment is not retrospective, and the Revenue's reliance on an alternate aerial distance measurement is rejected. Consequently, the impugned addition is deleted and the PCIT order set aside.
ITAT allows the assessee's appeal and quashes the PCIT's revisional order, holding that the revisional jurisdiction was improperly invoked where the AO adopted a plausible view on taxability of interest under s.28 of the Land Acquisition Act and the issue remained debatable. The Tribunal finds the order under challenge prompted solely by an audit objection and therefore unsustainable. On the question of capital gains, ITAT holds the land qualifies as a capital asset within s.2(14) for the relevant year; the Finance Act amendment is not retrospective, and the Revenue's reliance on an alternate aerial distance measurement is rejected. Consequently, the impugned addition is deleted and the PCIT order set aside.
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