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 u/s 263 passed by the PCIT. It held that the computation sheet forming part of the assessment order correctly reflected the net LTCG after reducing the LTCG already disclosed in the return, and that only the narrative portion of the assessment order contained an incorrect gross LTCG figure. As there was no error in the actual computation to render the assessment order erroneous or prejudicial to the interest of Revenue, the assumption of jurisdiction u/s 263 was held invalid.
ITAT allowed the assessee's appeal and quashed the revisionary order u/s 263 passed by the PCIT. It held that the computation sheet forming part of the assessment order correctly reflected the net LTCG after reducing the LTCG already disclosed in the return, and that only the narrative portion of the assessment order contained an incorrect gross LTCG figure. As there was no error in the actual computation to render the assessment order erroneous or prejudicial to the interest of Revenue, the assumption of jurisdiction u/s 263 was held invalid.
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