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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Validity of draft assessment order passed under Section 143(3) read with Section 144C - Since the jurisdictional aspect is not a pure question of law as arisen in this case and also taking note of the conduct of the assessee in the manner in which they have approached the problem, than what is being now focused before this Court, we are of the view that the appellant-assessee should definitely avail the remedy provided under the Act. - HC
Validity of draft assessment order passed under Section 143(3) read with Section 144C - Since the jurisdictional aspect is not a pure question of law as arisen in this case and also taking note of the conduct of the assessee in the manner in which they have approached the problem, than what is being now focused before this Court, we are of the view that the appellant-assessee should definitely avail the remedy provided under the Act. - HC
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