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 section 263 was examined: the twin conditions of the order being erroneous and prejudicial to revenue were not met because the Assessing Officer issued detailed queries, obtained submissions and documents, and applied his mind before accepting returned income. Explanation 2(a) did not apply as inquiries were made. Clause (d) of Explanation 2 could not be invoked since the AO adopted a plausible view supported by High Court precedents and the Supreme Court decision relied on was distinguishable on its facts. The Tribunal set aside the Principal Commissioner's revision order and allowed the assessee's appeal.
Revisional jurisdiction under section 263 was examined: the twin conditions of the order being erroneous and prejudicial to revenue were not met because the Assessing Officer issued detailed queries, obtained submissions and documents, and applied his mind before accepting returned income. Explanation 2(a) did not apply as inquiries were made. Clause (d) of Explanation 2 could not be invoked since the AO adopted a plausible view supported by High Court precedents and the Supreme Court decision relied on was distinguishable on its facts. The Tribunal set aside the Principal Commissioner's revision order and allowed the assessee's appeal.
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