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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Revision under s.263 was upheld on the ground that the assessment allowing deduction u/s 80G without enquiry into an allegedly bogus donation was erroneous and prejudicial to revenue. Mere production of a donation receipt was held insufficient to establish genuineness, especially when the Department possessed search-derived information indicating the donee entity's involvement in providing accommodation donations. Applying Explanation 2 to s.263, failure to conduct the necessary verification rendered the assessment order deemed erroneous; consequently, the revisional authority's direction for proper examination was sustained and the assessee's appeal was dismissed. - ITAT
Revision under s.263 was upheld on the ground that the assessment allowing deduction u/s 80G without enquiry into an allegedly bogus donation was erroneous and prejudicial to revenue. Mere production of a donation receipt was held insufficient to establish genuineness, especially when the Department possessed search-derived information indicating the donee entity's involvement in providing accommodation donations. Applying Explanation 2 to s.263, failure to conduct the necessary verification rendered the assessment order deemed erroneous; consequently, the revisional authority's direction for proper examination was sustained and the assessee's appeal was dismissed. - ITAT
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