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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Validity of assessment order - Nothing prevented officer to follow principles of natural justice which are conspicuously absent from the impugned order as it reflects only of affording two opportunities - It is also matter of concern that during the period when the appeals were taken up and dismissed in default there was already a threat of Corona Virus/COVID- 19 pandemic though the lock down only began on 24.03.2020 with a lock down of one day on 22.03.2020. - Matter restored back - HC
Validity of assessment order - Nothing prevented officer to follow principles of natural justice which are conspicuously absent from the impugned order as it reflects only of affording two opportunities - It is also matter of concern that during the period when the appeals were taken up and dismissed in default there was already a threat of Corona Virus/COVID- 19 pandemic though the lock down only began on 24.03.2020 with a lock down of one day on 22.03.2020. - Matter restored back - HC
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