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 section 263 was examined regarding additions for allegedly unexplained purchases/sales and allied issues. Where the seller's sales had already been accepted/settled in first appeal, the same transactions could not be treated as unexplained in the purchaser's hands, and the revisional direction could not nullify the CIT(A)'s finding; section 263 jurisdiction was held improperly exercised to that extent. However, for purchases from another supplier whose sales were not shown to have been accepted and where the AO had made a bogus sales addition after PMGKY surrender, the AO's enquiry was held incomplete, justifying set-aside for de novo consideration. The unexplained difference between audited P&L profit and computed income also warranted de novo examination, and audit-objection-based initiation was upheld. Appeal partly allowed. - ITAT
Revision under section 263 was examined regarding additions for allegedly unexplained purchases/sales and allied issues. Where the seller's sales had already been accepted/settled in first appeal, the same transactions could not be treated as unexplained in the purchaser's hands, and the revisional direction could not nullify the CIT(A)'s finding; section 263 jurisdiction was held improperly exercised to that extent. However, for purchases from another supplier whose sales were not shown to have been accepted and where the AO had made a bogus sales addition after PMGKY surrender, the AO's enquiry was held incomplete, justifying set-aside for de novo consideration. The unexplained difference between audited P&L profit and computed income also warranted de novo examination, and audit-objection-based initiation was upheld. Appeal partly allowed. - ITAT
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