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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In a limited scrutiny selected only to examine share premium, the AO made an addition u/s 68 for unexplained cash credit relating to share application money, thereby travelling beyond the permitted scope; the addition and consequential assessment were held unsustainable and the assessment was quashed as nullity. Separately, the statutory notice u/s 143(2) was issued by one jurisdictional officer, but the assessment was completed by a different officer without a valid notice foundation; the assessment was held without jurisdiction and void ab initio, and was quashed. - ITAT
In a limited scrutiny selected only to examine share premium, the AO made an addition u/s 68 for unexplained cash credit relating to share application money, thereby travelling beyond the permitted scope; the addition and consequential assessment were held unsustainable and the assessment was quashed as nullity. Separately, the statutory notice u/s 143(2) was issued by one jurisdictional officer, but the assessment was completed by a different officer without a valid notice foundation; the assessment was held without jurisdiction and void ab initio, and was quashed. - ITAT
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