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 quashed because the revising officer failed to record material or a basis to show the AO's assessment was erroneous and prejudicial to revenue; the tribunal found the AO had reasonably treated six funds as equity-oriented (entitling them to taxation under Section 112A) and that the assessee had furnished fund documentation and holding-period evidence. The tribunal also upheld the Assessing Officer's accepted Annual Letting Values for multiple properties where no contrary basis was shown by the reviser, and held penalty initiation lacked requisite material; quash subject to AO verifying purchase cost of the SBI Gold Fund.
Revision under section 263 was quashed because the revising officer failed to record material or a basis to show the AO's assessment was erroneous and prejudicial to revenue; the tribunal found the AO had reasonably treated six funds as equity-oriented (entitling them to taxation under Section 112A) and that the assessee had furnished fund documentation and holding-period evidence. The tribunal also upheld the Assessing Officer's accepted Annual Letting Values for multiple properties where no contrary basis was shown by the reviser, and held penalty initiation lacked requisite material; quash subject to AO verifying purchase cost of the SBI Gold Fund.
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