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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CBDT assigns specified Commissioners of Income-tax (Appeals) to exercise appellate jurisdiction over (i) appeals under sections 246A and 248 against assessments completed pursuant to search under section 132, requisition under section 132A, or survey under section 133A; (ii) appeals under sections 246A and 248 against assessments where additions or changes of income are based on material seized under sections 132/132A or impounded under section 133A; and (iii) appeals against penalty orders arising from cases in (i) or (ii). The assignment applies to persons/classes of persons falling within the jurisdiction of the listed income-tax authorities in prior notifications dated 22 October 2014, with headquarters and mapping to specified CIT(A) units set out in the Schedule, and takes effect from publication in the Official Gazette.
CBDT assigns specified Commissioners of Income-tax (Appeals) to exercise appellate jurisdiction over (i) appeals under sections 246A and 248 against assessments completed pursuant to search under section 132, requisition under section 132A, or survey under section 133A; (ii) appeals under sections 246A and 248 against assessments where additions or changes of income are based on material seized under sections 132/132A or impounded under section 133A; and (iii) appeals against penalty orders arising from cases in (i) or (ii). The assignment applies to persons/classes of persons falling within the jurisdiction of the listed income-tax authorities in prior notifications dated 22 October 2014, with headquarters and mapping to specified CIT(A) units set out in the Schedule, and takes effect from publication in the Official Gazette.
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