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...
Principles of natural justice - Since it has come on record through Ext.P7 itself that the petitioner was served with Ext.P6 notice, only on 24.03.2021, which contained the stipulation that he is given 15 days time, it was necessary to grant such period of time to file objections. Passing an order without complying with the period of time stipulated in Ext.P6 notice amounts to violation of natural justice. - HC
Principles of natural justice - Since it has come on record through Ext.P7 itself that the petitioner was served with Ext.P6 notice, only on 24.03.2021, which contained the stipulation that he is given 15 days time, it was necessary to grant such period of time to file objections. Passing an order without complying with the period of time stipulated in Ext.P6 notice amounts to violation of natural justice. - HC
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