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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Maintainability of appeal - monetary amount involved in the appeal - The learned Tribunal has powers to pass such orders on pending appeal before it, "as it thinks fit" and therefore, the power to remand the case back to the Adjudicating Authority is included within the amplitude of powers conferred upon the Tribunal by the Statute.
Maintainability of appeal - monetary amount involved in the appeal - The learned Tribunal has powers to pass such orders on pending appeal before it, "as it thinks fit" and therefore, the power to remand the case back to the Adjudicating Authority is included within the amplitude of powers conferred upon the Tribunal by the Statute.
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