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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Revisional jurisdiction under s.263 was invoked on the premise that the reassessment was erroneous and prejudicial because the AO allegedly failed to consider an order under s.92CA(3) and verify the arm's length price of royalty. Since no s.92CA(3) order was ever passed, the alleged error was legally untenable, and the AO, having made a reference, could not himself substitute the TPO's specialized determination, consistent with s.92CA(4) ("if any"). Further, s.263 could not be used to compel a fresh ALP determination after the TPO's power stood exhausted by limitation under s.92CA(3A). The revision was quashed and the assessee's appeal allowed - ITAT
Revisional jurisdiction under s.263 was invoked on the premise that the reassessment was erroneous and prejudicial because the AO allegedly failed to consider an order under s.92CA(3) and verify the arm's length price of royalty. Since no s.92CA(3) order was ever passed, the alleged error was legally untenable, and the AO, having made a reference, could not himself substitute the TPO's specialized determination, consistent with s.92CA(4) ("if any"). Further, s.263 could not be used to compel a fresh ALP determination after the TPO's power stood exhausted by limitation under s.92CA(3A). The revision was quashed and the assessee's appeal allowed - ITAT
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