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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Levy of penalty on additions of admitted amount during assessment proceedings - CIT(A) deleted the penalty - Company has already liquidated - when the respondent company has already gone into liquidation and is no more in existence the present appeal filed by the Revenue is not maintainable in the present format as liquidator has not come up before the Tribunal despite numerous notices to file the amended form 36A in the present appeal. So in these circumstances present appeal is not maintainable in the present format. - AT
Levy of penalty on additions of admitted amount during assessment proceedings - CIT(A) deleted the penalty - Company has already liquidated - when the respondent company has already gone into liquidation and is no more in existence the present appeal filed by the Revenue is not maintainable in the present format as liquidator has not come up before the Tribunal despite numerous notices to file the amended form 36A in the present appeal. So in these circumstances present appeal is not maintainable in the present format. - AT
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