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...
Faceless Assessment - Whether it cannot be gainsaid that one day time given qua SCN is too short - The first point urged i.e., a mere one day time qua SCN under the normal circumstances would have certainly been a formidable argument, but not in this case qua writ petitioner as writ petitioner has a) chosen to reply on the very next day i.e., 22.09.2021 and has also not chosen to ask for a personal hearing vide sub-paragraph (c) of Paragraph 3 of SCN. This draws the curtains on the first point. - HC
Faceless Assessment - Whether it cannot be gainsaid that one day time given qua SCN is too short - The first point urged i.e., a mere one day time qua SCN under the normal circumstances would have certainly been a formidable argument, but not in this case qua writ petitioner as writ petitioner has a) chosen to reply on the very next day i.e., 22.09.2021 and has also not chosen to ask for a personal hearing vide sub-paragraph (c) of Paragraph 3 of SCN. This draws the curtains on the first point. - HC
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