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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Reassessment under section 147/148 was quashed because applying the Assessing Officer's own gross profit rate (13.85%) produced alleged escaped income of Rs.48,09,503, below the statutory monetary threshold of Rs.50,00,000 under section 149(1)(b), and "income chargeable to tax which has escaped assessment" refers to real income, not gross transaction value. On merits, the assessee produced primary documents and bank payment evidence which AO did not independently test; books were not rejected under section 145(3), and a separate addition would duplicate profit already reflected in returned income. Appeal allowed by ITAT.
Reassessment under section 147/148 was quashed because applying the Assessing Officer's own gross profit rate (13.85%) produced alleged escaped income of Rs.48,09,503, below the statutory monetary threshold of Rs.50,00,000 under section 149(1)(b), and "income chargeable to tax which has escaped assessment" refers to real income, not gross transaction value. On merits, the assessee produced primary documents and bank payment evidence which AO did not independently test; books were not rejected under section 145(3), and a separate addition would duplicate profit already reflected in returned income. Appeal allowed by ITAT.
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