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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Condonation of Delay of 402 days - We note that the assessee is a District Central Co-op. Bank, managed by highly qualified officers and well trained professionals in respect of accounts and litigation. Therefore, statement of, that the impugned order was misplaced due to shifting of assessee’s office to head office building is a mere statement without any evidence made for the purpose of filing the said affidavit. - AT
Condonation of Delay of 402 days - We note that the assessee is a District Central Co-op. Bank, managed by highly qualified officers and well trained professionals in respect of accounts and litigation. Therefore, statement of, that the impugned order was misplaced due to shifting of assessee’s office to head office building is a mere statement without any evidence made for the purpose of filing the said affidavit. - AT
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