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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Principles of natural justice - condonation of delay of 75 days in filing appeal - appeal decided in absence of counsel for the appellant - Such order rejecting the application on merit behind the back of the appellant could not have been passed by the learned Member. At the most the matter could have been posted for dismissal in default. It appears that the learned Member has not followed the basic principles of natural justice in passing the impugned order. - HC
Principles of natural justice - condonation of delay of 75 days in filing appeal - appeal decided in absence of counsel for the appellant - Such order rejecting the application on merit behind the back of the appellant could not have been passed by the learned Member. At the most the matter could have been posted for dismissal in default. It appears that the learned Member has not followed the basic principles of natural justice in passing the impugned order. - HC
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