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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Restoration of appeal - Dismissal of appeal for non-compliance and also for non-appearance exparte, should not deprive the parties to contest the order on merits when delay in filing the restoration application has been explained and the contesting parties should not suffer for lapses on the part of their counsel - AT
Restoration of appeal - Dismissal of appeal for non-compliance and also for non-appearance exparte, should not deprive the parties to contest the order on merits when delay in filing the restoration application has been explained and the contesting parties should not suffer for lapses on the part of their counsel - AT
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