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" ?
ITAT held that the revisionary orders passed by PCIT under s.263 were ultravires and unsustainable. The Tribunal found that the AO, in assessments framed under s.153A, did not make additions based on any incriminating material seized in the search, nor did the PCIT's s.263 order record reliance on such material. The PCIT's examination of the assessee's entitlement to deduction under s.80IC went beyond the scope of the s.153A assessment and thus outside the jurisdictional ambit of s.263. Consequently, the s.263 order was quashed as erroneous for lack of statutory mandate; the Tribunal did not adjudicate on the substantive merits of the s.80IC claim.
ITAT held that the revisionary orders passed by PCIT under s.263 were ultravires and unsustainable. The Tribunal found that the AO, in assessments framed under s.153A, did not make additions based on any incriminating material seized in the search, nor did the PCIT's s.263 order record reliance on such material. The PCIT's examination of the assessee's entitlement to deduction under s.80IC went beyond the scope of the s.153A assessment and thus outside the jurisdictional ambit of s.263. Consequently, the s.263 order was quashed as erroneous for lack of statutory mandate; the Tribunal did not adjudicate on the substantive merits of the s.80IC claim.
Note: It is a system-generated summary and is for quick reference only.