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 upheld the PCIT's revision u/s 263 for AY 2020-21, holding the assessment order erroneous and prejudicial to the interests of Revenue due to non-examination of depreciation claimed on goodwill. The assessee's contention that the tax audit report sufficed and that no further enquiry by AO was needed was rejected. ITAT confined the validity of revision to the year under consideration and held that PCIT's observations regarding earlier years would not bind the set-aside proceedings, though they may guide Revenue separately. The direction to AO to verify the depreciation claim on goodwill was sustained. The objection regarding absence of DIN in the s.263 notice was also rejected.
ITAT upheld the PCIT's revision u/s 263 for AY 2020-21, holding the assessment order erroneous and prejudicial to the interests of Revenue due to non-examination of depreciation claimed on goodwill. The assessee's contention that the tax audit report sufficed and that no further enquiry by AO was needed was rejected. ITAT confined the validity of revision to the year under consideration and held that PCIT's observations regarding earlier years would not bind the set-aside proceedings, though they may guide Revenue separately. The direction to AO to verify the depreciation claim on goodwill was sustained. The objection regarding absence of DIN in the s.263 notice was also rejected.
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