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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Effective opportunity - Courts have consistently interpreted the phrase 'effective opportunity' to mean and include an opportunity of personal hearing as well. In this case, since admittedly the petitioner has not been heard in person, the impugned order has been passed in violation of principles of natural justice and without affording adequate opportunity of personal hearing to put forth its case - HC
Effective opportunity - Courts have consistently interpreted the phrase 'effective opportunity' to mean and include an opportunity of personal hearing as well. In this case, since admittedly the petitioner has not been heard in person, the impugned order has been passed in violation of principles of natural justice and without affording adequate opportunity of personal hearing to put forth its case - HC
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