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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Rectification of mistake u/s 254 - Period of limitation would begin to run from the date the assessee got knowledge of the order or from the date of passing of the order - The period of limitation would thus commence only from 19.11.2019 which is the date of obtaining knowledge of the order dated 01.02.2013. The period spent by the assessee after it got knowledge of the dismissal of its appeals in limine from November 2019 to March-2020 is the period spent in prosecuting the remedy provided under the said Act. From the aforesaid we are satisfied that the time spent from 19.11.2019 till filing of the present appeals has been sufficiently explained by the applicants. - HC
Rectification of mistake u/s 254 - Period of limitation would begin to run from the date the assessee got knowledge of the order or from the date of passing of the order - The period of limitation would thus commence only from 19.11.2019 which is the date of obtaining knowledge of the order dated 01.02.2013. The period spent by the assessee after it got knowledge of the dismissal of its appeals in limine from November 2019 to March-2020 is the period spent in prosecuting the remedy provided under the said Act. From the aforesaid we are satisfied that the time spent from 19.11.2019 till filing of the present appeals has been sufficiently explained by the applicants. - HC
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