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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Requirement of pre-deposit - The appellant has not made the pre-deposit and has filed an application seeking waiver because of financial constraints and for the reason that the appellant has a good case on merits - As the law relating to pre-deposit has been settled by the Supreme Court and the High Courts, it would also not be possible to accept the prayer made by the learned counsel for the appellant that the application should not be decided at this stage as the matter in the case of a co-noticee, after his plea for waiver of pre-deposit had been rejected by the Tribunal and the High Court had maintained the order of the Tribunal, is pending in Supreme Court. - The application filed for waiver of pre-deposit is rejected - As the application has been rejected, the appeal stands dismissed - AT
Requirement of pre-deposit - The appellant has not made the pre-deposit and has filed an application seeking waiver because of financial constraints and for the reason that the appellant has a good case on merits - As the law relating to pre-deposit has been settled by the Supreme Court and the High Courts, it would also not be possible to accept the prayer made by the learned counsel for the appellant that the application should not be decided at this stage as the matter in the case of a co-noticee, after his plea for waiver of pre-deposit had been rejected by the Tribunal and the High Court had maintained the order of the Tribunal, is pending in Supreme Court. - The application filed for waiver of pre-deposit is rejected - As the application has been rejected, the appeal stands dismissed - AT
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