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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Rectification u/s 254 - non consideration of the Judgment of the Hon'ble Bombay High Court - When the Tribunal has no jurisdiction to review the order passed by them, the remedy open to the assessee is to file an appeal against the order, if they are aggrieved over the same. The order passed by the Tribunal is beyond the scope of section 254(2). In these circumstances, the Tribunal should not have allowed the Miscellaneous Application. - HC
Rectification u/s 254 - non consideration of the Judgment of the Hon'ble Bombay High Court - When the Tribunal has no jurisdiction to review the order passed by them, the remedy open to the assessee is to file an appeal against the order, if they are aggrieved over the same. The order passed by the Tribunal is beyond the scope of section 254(2). In these circumstances, the Tribunal should not have allowed the Miscellaneous Application. - HC
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