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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Revision under section 263 was held unsustainable because the Assessing Officer had properly examined the relevant material, accepted the assessee's project completion method, and adopted one permissible view on the taxability of on-money from the Spring-II project. The Court reiterated that revision is available only when the assessment order is both erroneous and prejudicial to the interests of the Revenue; a mere difference of opinion cannot justify interference where enquiries were made and the view taken was plausible. No material showed that the amount was taxable in the relevant assessment year, so the appeal was dismissed and no substantial question of law arose.
Revision under section 263 was held unsustainable because the Assessing Officer had properly examined the relevant material, accepted the assessee's project completion method, and adopted one permissible view on the taxability of on-money from the Spring-II project. The Court reiterated that revision is available only when the assessment order is both erroneous and prejudicial to the interests of the Revenue; a mere difference of opinion cannot justify interference where enquiries were made and the view taken was plausible. No material showed that the amount was taxable in the relevant assessment year, so the appeal was dismissed and no substantial question of law arose.
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