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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ITAT held that an appeal against a rectification order under section 154 cannot be used to challenge the original addition where the rectification merely corrected a computation mistake apparent from the record and did not disturb the substantive assessment. As the assessee's grievance was in substance against the addition itself, the proper remedy was to appeal the original assessment order, not the rectification order. The appeal against the rectification order was therefore rightly dismissed. The Tribunal clarified that this dismissal would not prevent the assessee from separately challenging the original assessment order in accordance with law, subject to limitation, with all contentions left open.
ITAT held that an appeal against a rectification order under section 154 cannot be used to challenge the original addition where the rectification merely corrected a computation mistake apparent from the record and did not disturb the substantive assessment. As the assessee's grievance was in substance against the addition itself, the proper remedy was to appeal the original assessment order, not the rectification order. The appeal against the rectification order was therefore rightly dismissed. The Tribunal clarified that this dismissal would not prevent the assessee from separately challenging the original assessment order in accordance with law, subject to limitation, with all contentions left open.
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