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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Condonation of delay of 21 days in filing appeal - The delay of 21 days in filing the appeal before Commissioner (Appeals) is not an inordinate delay and is not intentional and the appellant does not stand to gain anything by filing the appeal with the delay and the approach of the various Courts is that the delay should be liberally condoned and matters should be decided on merits - AT
Condonation of delay of 21 days in filing appeal - The delay of 21 days in filing the appeal before Commissioner (Appeals) is not an inordinate delay and is not intentional and the appellant does not stand to gain anything by filing the appeal with the delay and the approach of the various Courts is that the delay should be liberally condoned and matters should be decided on merits - AT
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