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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In limited scrutiny, the AO's jurisdiction is confined to the specific issues for which the case was selected. The Tribunal found that the scrutiny parameter referred only to transfer of property by the assessee and did not extend to acquisition or purchase of property. As there was no material showing a valid conversion of the assessment into complete scrutiny with approval of the competent authority, the addition for alleged unexplained investment in purchase of immovable property was beyond jurisdiction and contrary to the CBDT circular governing scrutiny assessments. The addition was therefore deleted and the appellate order set aside.
In limited scrutiny, the AO's jurisdiction is confined to the specific issues for which the case was selected. The Tribunal found that the scrutiny parameter referred only to transfer of property by the assessee and did not extend to acquisition or purchase of property. As there was no material showing a valid conversion of the assessment into complete scrutiny with approval of the competent authority, the addition for alleged unexplained investment in purchase of immovable property was beyond jurisdiction and contrary to the CBDT circular governing scrutiny assessments. The addition was therefore deleted and the appellate order set aside.
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