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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Service of limited notice - the Appellant has been served copy of the Application under Section 95(1) as per the requirements of the statute and since the Appellant was well aware of the date and appeared on the date before the Adjudicating Authority, we see no reason to direct for issue of any limited notice to the Appellant, he being aware of the proceedings. The stage of admission or rejection of the Application has not yet arrived and at the stage of admission or rejection of the Application, the Appellant can raise all the objections before the Adjudicating Authority opposing the admission of the Application. - AT
Service of limited notice - the Appellant has been served copy of the Application under Section 95(1) as per the requirements of the statute and since the Appellant was well aware of the date and appeared on the date before the Adjudicating Authority, we see no reason to direct for issue of any limited notice to the Appellant, he being aware of the proceedings. The stage of admission or rejection of the Application has not yet arrived and at the stage of admission or rejection of the Application, the Appellant can raise all the objections before the Adjudicating Authority opposing the admission of the Application. - AT
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