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 assessee's appeal and quashed the revisionary order passed u/s 263. It held that the PCIT's assumption of jurisdiction was invalid, as no independent inquiry, verification, or examination of evidence was undertaken beyond the existing assessment record. The PCIT merely reproduced the AO's show cause notice and portions of the assessee's reply without analyzing or rebutting the material filed. ITAT observed that the AO had conducted inquiries, adopted a possible view in law, and obtained prior approval of the Addl. CIT. In such circumstances, the PCIT could not invoke s.263 on a vague allegation of inadequate inquiry without demonstrating any specific error rendering the assessment order erroneous and prejudicial to the Revenue.
ITAT allowed the assessee's appeal and quashed the revisionary order passed u/s 263. It held that the PCIT's assumption of jurisdiction was invalid, as no independent inquiry, verification, or examination of evidence was undertaken beyond the existing assessment record. The PCIT merely reproduced the AO's show cause notice and portions of the assessee's reply without analyzing or rebutting the material filed. ITAT observed that the AO had conducted inquiries, adopted a possible view in law, and obtained prior approval of the Addl. CIT. In such circumstances, the PCIT could not invoke s.263 on a vague allegation of inadequate inquiry without demonstrating any specific error rendering the assessment order erroneous and prejudicial to the Revenue.
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