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 held that the revision under section 263 was unsustainable and the impugned revisionary order was set aside; the assessment framed by the AO was restored and the appeal allowed. The Tribunal found the assessee had furnished detailed explanations on the record and the AO had examined the identified aspects and taken one possible view; absence of elaborate discussion in the AO's order did not render it "erroneous and prejudicial to the interests of the revenue." Principal CIT failed to make independent findings demonstrating how non-examination of newly asserted issues rendered the assessment erroneous and prejudicial. Consequently, further inquiry or fresh determination under section 263 was not warranted.
ITAT held that the revision under section 263 was unsustainable and the impugned revisionary order was set aside; the assessment framed by the AO was restored and the appeal allowed. The Tribunal found the assessee had furnished detailed explanations on the record and the AO had examined the identified aspects and taken one possible view; absence of elaborate discussion in the AO's order did not render it "erroneous and prejudicial to the interests of the revenue." Principal CIT failed to make independent findings demonstrating how non-examination of newly asserted issues rendered the assessment erroneous and prejudicial. Consequently, further inquiry or fresh determination under section 263 was not warranted.
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