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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Where registered sale deeds were cancelled and consideration reversed but those documents were not placed before the assessing officer during assessment proceedings, cancelled transactions were treated as not giving rise to taxable income. The document stresses that evidence of cancellation and reversal, when first produced only before the court, defeats assessment orders premised on the original transactions. The assessing officer's failure to consider cancellation and reversal rendered impugned assessment orders unsustainable, resulting in quashing and setting aside of those orders and disposal in light of the cited precedent.
Where registered sale deeds were cancelled and consideration reversed but those documents were not placed before the assessing officer during assessment proceedings, cancelled transactions were treated as not giving rise to taxable income. The document stresses that evidence of cancellation and reversal, when first produced only before the court, defeats assessment orders premised on the original transactions. The assessing officer's failure to consider cancellation and reversal rendered impugned assessment orders unsustainable, resulting in quashing and setting aside of those orders and disposal in light of the cited precedent.
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