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 order of Appellate Tribunal passed without dealing with any of the submissions made by the appellant - It is evident that the Tribunal has merely relied on the judgment of the Hon'ble Supreme Court in the case of DOABA STEEL ROLLING MILLS and has not even assigned any reason as to how the decision applies to the fact situation of the case - Thus, it is found that the order passed by the Tribunal is cryptic and suffers from the vice of non-application of mind. - HC
Principles of natural Justice - the order of Appellate Tribunal passed without dealing with any of the submissions made by the appellant - It is evident that the Tribunal has merely relied on the judgment of the Hon'ble Supreme Court in the case of DOABA STEEL ROLLING MILLS and has not even assigned any reason as to how the decision applies to the fact situation of the case - Thus, it is found that the order passed by the Tribunal is cryptic and suffers from the vice of non-application of mind. - HC
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