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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Violation of principles of Natural Justice - Validity of assessment order - Office of the assessee was closed due to lockdown - While on one hand the petitioners acted in consonance / compliance with the Government order issued to prevent and contain the spread of virus, the assessing authority on the other hand fastened the petitioners with the liability to tax by passing the impugned order of assessment, behind their back. The said action on the part of the respondent authorities cannot be upheld even though the authority may have compelling reasons to do so, having regard to the limitation to make assessment getting over - HC
Violation of principles of Natural Justice - Validity of assessment order - Office of the assessee was closed due to lockdown - While on one hand the petitioners acted in consonance / compliance with the Government order issued to prevent and contain the spread of virus, the assessing authority on the other hand fastened the petitioners with the liability to tax by passing the impugned order of assessment, behind their back. The said action on the part of the respondent authorities cannot be upheld even though the authority may have compelling reasons to do so, having regard to the limitation to make assessment getting over - HC
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