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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Principles of Natural Justice - The Commissioner (Appeals) did not have any proof of the postal department regarding service of the letter dated January 10, 2018 and only a presumption has been drawn by the Commissioner (Appeals) that since the letter dated January 10, 2018 was sent by speed post, it must have been delivered prior to January 23, 2018. In the absence of the any documentary proof regarding service of the letter January 10, 2018 upon the appellant, the Commissioner (Appeals) was not justified in forming such an opinion and refusing adjournment to the appellant. - AT
Principles of Natural Justice - The Commissioner (Appeals) did not have any proof of the postal department regarding service of the letter dated January 10, 2018 and only a presumption has been drawn by the Commissioner (Appeals) that since the letter dated January 10, 2018 was sent by speed post, it must have been delivered prior to January 23, 2018. In the absence of the any documentary proof regarding service of the letter January 10, 2018 upon the appellant, the Commissioner (Appeals) was not justified in forming such an opinion and refusing adjournment to the appellant. - AT
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