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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Authorization by committee of commissioner - appeal before tribunal - The intent and spirit of the law is that the committee has to thread bare examine the issues/points which has caused prejudice to the interest of Revenue and with proper reason shall come to a conclusion that the order appealed is neither legal or proper for which remedy of appeal by Revenue is to be sought. Unless such process known to law is followed, we shall have no hesitation to dismiss the appeal of Revenue.... - AT
Authorization by committee of commissioner - appeal before tribunal - The intent and spirit of the law is that the committee has to thread bare examine the issues/points which has caused prejudice to the interest of Revenue and with proper reason shall come to a conclusion that the order appealed is neither legal or proper for which remedy of appeal by Revenue is to be sought. Unless such process known to law is followed, we shall have no hesitation to dismiss the appeal of Revenue.... - AT
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