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...
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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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Section 142A permits a reference to the Valuation Officer only in the course of making an assessment or reassessment, and only where the Assessing Officer has material showing that the assessee's valuation is unreliable. The provision cannot be used to collect information for reopening assessment. Where the books of account are neither rejected nor found defective, the Assessing Officer cannot rely solely on the DVO's report to make additions. On these facts, the valuation reference made during reopening, and the additions based on it, were held unsustainable, and the Tribunal's order was affirmed.
Section 142A permits a reference to the Valuation Officer only in the course of making an assessment or reassessment, and only where the Assessing Officer has material showing that the assessee's valuation is unreliable. The provision cannot be used to collect information for reopening assessment. Where the books of account are neither rejected nor found defective, the Assessing Officer cannot rely solely on the DVO's report to make additions. On these facts, the valuation reference made during reopening, and the additions based on it, were held unsustainable, and the Tribunal's order was affirmed.
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