Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Transfer pricing comparability was addressed by excluding Unik Techno Systems Pvt. Ltd. as a valid comparable because functional dissimilarity (manufacturer of battery-production machines versus assessee's activities) rendered it unsuitable; the AO/TPO is directed to recompute ALP without that entity. Separately, the appellate body admitted fresh grounds contending that an excise duty exemption may constitute a non taxable capital receipt and remitted that substantive issue to the assessing officer for factual verification of scheme intent, eligibility and amounts, treatment under normal provisions and AMT, and for fresh decision after affording the assessee opportunity to be heard.
Transfer pricing comparability was addressed by excluding Unik Techno Systems Pvt. Ltd. as a valid comparable because functional dissimilarity (manufacturer of battery-production machines versus assessee's activities) rendered it unsuitable; the AO/TPO is directed to recompute ALP without that entity. Separately, the appellate body admitted fresh grounds contending that an excise duty exemption may constitute a non taxable capital receipt and remitted that substantive issue to the assessing officer for factual verification of scheme intent, eligibility and amounts, treatment under normal provisions and AMT, and for fresh decision after affording the assessee opportunity to be heard.
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