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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Failure to take any action by the department after the Tribunal set aside the order of the DRP and also the assessment order The matter was restored to the file of the Assessing Officer with a direction to pass a fresh assessment order in accordance with law - It is very unfortunate to note that although the writ applicant has been knocking the doors of the Deputy Commissioner of the Income Tax, Vadodara, past almost two years, yet the Deputy Commissioner has not even bothered to give any formal reply to even one of the representations. - HC
Failure to take any action by the department after the Tribunal set aside the order of the DRP and also the assessment order The matter was restored to the file of the Assessing Officer with a direction to pass a fresh assessment order in accordance with law - It is very unfortunate to note that although the writ applicant has been knocking the doors of the Deputy Commissioner of the Income Tax, Vadodara, past almost two years, yet the Deputy Commissioner has not even bothered to give any formal reply to even one of the representations. - HC
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