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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Condonation of delay in filing petition - No explanation is adduced for the elapse in time between 04.06.2016 and date of filing of this writ petition which is 08.10.2020 and in the light of the materials produced by the revenue to establish service, which are also not denied by the petitioner, no justification found to entertain these writ petitions and the same are dismissed in limine. - HC
Condonation of delay in filing petition - No explanation is adduced for the elapse in time between 04.06.2016 and date of filing of this writ petition which is 08.10.2020 and in the light of the materials produced by the revenue to establish service, which are also not denied by the petitioner, no justification found to entertain these writ petitions and the same are dismissed in limine. - HC
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