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, consequent to search u/s 132, the AO was mandatorily required to proceed under the special reassessment regime u/s 147/148 (read with Expl. 2(iv) to s.148) with prior approval u/s 148B, and could not validly complete the pending scrutiny u/s 143(3). The approval purportedly granted u/s 153D was found to be mechanical and without proper application of mind, vitiating the assessment for lack of jurisdiction. The impugned assessment order was therefore declared void and annulled. On merits, in the alternative, ITAT upheld addition towards unexplained opening balance and 20% of unmatched seized entries, but directed recomputation of trading addition by applying a 14% gross profit rate instead of 14.12%/23.85%, to operate only if the jurisdictional defect is overturned by a higher forum.
ITAT held that, consequent to search u/s 132, the AO was mandatorily required to proceed under the special reassessment regime u/s 147/148 (read with Expl. 2(iv) to s.148) with prior approval u/s 148B, and could not validly complete the pending scrutiny u/s 143(3). The approval purportedly granted u/s 153D was found to be mechanical and without proper application of mind, vitiating the assessment for lack of jurisdiction. The impugned assessment order was therefore declared void and annulled. On merits, in the alternative, ITAT upheld addition towards unexplained opening balance and 20% of unmatched seized entries, but directed recomputation of trading addition by applying a 14% gross profit rate instead of 14.12%/23.85%, to operate only if the jurisdictional defect is overturned by a higher forum.
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