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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Validity of Best judgement assessment u/s 144 - the responsibility of the assessee does not end by merely appointing a Counsel. The assessee necessarily needs to ensure and make available all necessary informations to its counsel for enabling him to participate effectively in the hearing. However, in view of the peculiar facts of the present case, considering the oral undertaking given we do not insist on an affidavit of the assessee. Having expressed our displeasure on the lax attitude evident on record, accepting the oral undertaking given, we deem it appropriate to direct a remand. At the same time at this stage we deem it necessary to highlight that a Government Corporation is like any other assessee before the tax authority and cannot be allowed to plead that on this count it be given a preferential treatment and be allowed to escape the responsibilities of representing their case before the other governmental authorities including the tax authorities. - AT
Validity of Best judgement assessment u/s 144 - the responsibility of the assessee does not end by merely appointing a Counsel. The assessee necessarily needs to ensure and make available all necessary informations to its counsel for enabling him to participate effectively in the hearing. However, in view of the peculiar facts of the present case, considering the oral undertaking given we do not insist on an affidavit of the assessee. Having expressed our displeasure on the lax attitude evident on record, accepting the oral undertaking given, we deem it appropriate to direct a remand. At the same time at this stage we deem it necessary to highlight that a Government Corporation is like any other assessee before the tax authority and cannot be allowed to plead that on this count it be given a preferential treatment and be allowed to escape the responsibilities of representing their case before the other governmental authorities including the tax authorities. - AT
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