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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Transfer of case u/s 127 - The Revenue authorities are the best judge in this matter and they have assigned clear and cogent reasons as to why the transfer is being made. The only requirement of the law is that while passing an order of transfer, the reasons must be assigned. We have absolutely no doubt in our mind that cogent reasons have been assigned by the Revenue for transferring the case from Dimapur to Kollam and therefore, it does not call for our interference. - HC
Transfer of case u/s 127 - The Revenue authorities are the best judge in this matter and they have assigned clear and cogent reasons as to why the transfer is being made. The only requirement of the law is that while passing an order of transfer, the reasons must be assigned. We have absolutely no doubt in our mind that cogent reasons have been assigned by the Revenue for transferring the case from Dimapur to Kollam and therefore, it does not call for our interference. - HC
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