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...
Working capital adjustment in a transfer pricing giving-effect order required proper evidentiary substantiation. The Court noted that the earlier direction to reconsider the claim was not enough because the petitioner failed to comply with the later requisition for working capital details and their impact on profit, and had only furnished an Excel calculation of the adjusted margin. Mere calculations were insufficient; the claim had to be authenticated with supporting documents duly certified by a Chartered Accountant. The matter was therefore remitted for fresh consideration on merits, with liberty to upload the required particulars and an opportunity of hearing before a fresh order was passed.
Working capital adjustment in a transfer pricing giving-effect order required proper evidentiary substantiation. The Court noted that the earlier direction to reconsider the claim was not enough because the petitioner failed to comply with the later requisition for working capital details and their impact on profit, and had only furnished an Excel calculation of the adjusted margin. Mere calculations were insufficient; the claim had to be authenticated with supporting documents duly certified by a Chartered Accountant. The matter was therefore remitted for fresh consideration on merits, with liberty to upload the required particulars and an opportunity of hearing before a fresh order was passed.
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