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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Appellate authorities must decide an income-tax appeal on its merits where it has not been withdrawn, notwithstanding the assessee's non-prosecution or failure to make further compliance. Dismissal without examining grounds challenging reassessment and additions for unexplained bank credits fails to discharge the appellate duty to adjudicate the issues raised. Challenges concerning audited books, business history and bank withdrawals require consideration after providing an opportunity to substantiate the contentions and produce supporting material. The appeal was restored for fresh appellate adjudication in accordance with law.
Appellate authorities must decide an income-tax appeal on its merits where it has not been withdrawn, notwithstanding the assessee's non-prosecution or failure to make further compliance. Dismissal without examining grounds challenging reassessment and additions for unexplained bank credits fails to discharge the appellate duty to adjudicate the issues raised. Challenges concerning audited books, business history and bank withdrawals require consideration after providing an opportunity to substantiate the contentions and produce supporting material. The appeal was restored for fresh appellate adjudication in accordance with law.
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