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...
Appeal before the CIT(A) against the draft order - It is only the appeal filed by the assessee against the order u/s 144C(3) passed by the AO on 23.01.2020 that an effective and legally tenable appeal would call for decision. In our considered opinion, the ld. CIT(A) took an unimpeachable view in treating the appeal against the draft order as ‘defective’ and thus ‘not maintainable’.- AT
Appeal before the CIT(A) against the draft order - It is only the appeal filed by the assessee against the order u/s 144C(3) passed by the AO on 23.01.2020 that an effective and legally tenable appeal would call for decision. In our considered opinion, the ld. CIT(A) took an unimpeachable view in treating the appeal against the draft order as ‘defective’ and thus ‘not maintainable’.- AT
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