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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Condonation of delay in filing appeal - appeal has been rejected as being filed beyond the stipulated period without any genuine reason - Catena of decisions have already held that there cannot be straight jacket formula to define the word ‘sufficient cause’ or which can be applied to all cases without reference to the peculiar facts and facts and circumstances of a given case. - In the present matter since there is no substantial delay nor it was beyond such period as was not condonable by Commissioner (Appeals). - Commissioner (Appeals) has failed to observe proviso to section 85 (3) A of the Finance Act, 1994. - AT
Condonation of delay in filing appeal - appeal has been rejected as being filed beyond the stipulated period without any genuine reason - Catena of decisions have already held that there cannot be straight jacket formula to define the word ‘sufficient cause’ or which can be applied to all cases without reference to the peculiar facts and facts and circumstances of a given case. - In the present matter since there is no substantial delay nor it was beyond such period as was not condonable by Commissioner (Appeals). - Commissioner (Appeals) has failed to observe proviso to section 85 (3) A of the Finance Act, 1994. - AT
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