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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Levy of late fee u/s 234E - The order of the A.O. can be challenged only if the A.O. has failed to comply with the mandatory provisions of Section 200A r.w.s. 234E of the Act while making adjustment and issuing the intimation. In absence of any such allegation by the assessee that the A.O. has violated any of the provisions of Section 200A as well as Section 234E adjustment made by the A.O. on account of late fee U/s 234E of the Act cannot be deleted. - AT
Levy of late fee u/s 234E - The order of the A.O. can be challenged only if the A.O. has failed to comply with the mandatory provisions of Section 200A r.w.s. 234E of the Act while making adjustment and issuing the intimation. In absence of any such allegation by the assessee that the A.O. has violated any of the provisions of Section 200A as well as Section 234E adjustment made by the A.O. on account of late fee U/s 234E of the Act cannot be deleted. - AT
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