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 allowed the appeal, holding the PCIT's revision under s.263 invalid and quashing the s.263 order. The Tribunal found the AO had conducted requisite enquiries during the s.143(3) assessment, considered documentary evidence and law, and legitimately accepted the assessee's claim regarding payments to foreign agents and non-applicability of s.195 r.w.s.9. The prerequisites for invoking s.263-an order both erroneous and prejudicial to revenue-were not satisfied, and the show-cause notice lacked particulars and denied the assessee an opportunity on the verification direction, vitiating the proceedings. Consequently the direction to annul the assessment and reframe it was held bad in law.
ITAT allowed the appeal, holding the PCIT's revision under s.263 invalid and quashing the s.263 order. The Tribunal found the AO had conducted requisite enquiries during the s.143(3) assessment, considered documentary evidence and law, and legitimately accepted the assessee's claim regarding payments to foreign agents and non-applicability of s.195 r.w.s.9. The prerequisites for invoking s.263-an order both erroneous and prejudicial to revenue-were not satisfied, and the show-cause notice lacked particulars and denied the assessee an opportunity on the verification direction, vitiating the proceedings. Consequently the direction to annul the assessment and reframe it was held bad in law.
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