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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E-Proceeding facility introduced by the Income Tax Department - Single member bench of the HC granted relief to the assessee - There is nothing placed before us to show that the respondent herein-assessee made a specific request in terms of paragraph 4 of the above Note stating that they require a physical hearing for a particular reason. In such circumstances, the sweeping observations and remarks are not called for especially when the system has been implemented and all the assessee through out the country have switched over from manual procedure to e-procedure - HC
E-Proceeding facility introduced by the Income Tax Department - Single member bench of the HC granted relief to the assessee - There is nothing placed before us to show that the respondent herein-assessee made a specific request in terms of paragraph 4 of the above Note stating that they require a physical hearing for a particular reason. In such circumstances, the sweeping observations and remarks are not called for especially when the system has been implemented and all the assessee through out the country have switched over from manual procedure to e-procedure - HC
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