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...
Transfer pricing analysis under External TNMM remained the proper benchmarking method where the earlier remand had already excluded Internal TNMM and limited scrutiny to the comparables selected by the assessee. The text explains that mechanical turnover, export and product-difference filters could not justify wiping out the external comparable set for a limited-risk contract manufacturer earning a cost-plus return, and that comparable selection must reflect functions, assets and risks. It further states that AE and Non-AE segments were not internally comparable because the Non-AE business was entrepreneurial and risk-bearing, while audited segmental accounts could not be reworked absent specific defects. On that basis, the segmental results were restored and the transfer pricing adjustments were deleted.
Transfer pricing analysis under External TNMM remained the proper benchmarking method where the earlier remand had already excluded Internal TNMM and limited scrutiny to the comparables selected by the assessee. The text explains that mechanical turnover, export and product-difference filters could not justify wiping out the external comparable set for a limited-risk contract manufacturer earning a cost-plus return, and that comparable selection must reflect functions, assets and risks. It further states that AE and Non-AE segments were not internally comparable because the Non-AE business was entrepreneurial and risk-bearing, while audited segmental accounts could not be reworked absent specific defects. On that basis, the segmental results were restored and the transfer pricing adjustments were deleted.
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