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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Refund - Failure of the authority of pass fresh de-novo order in remand proceedings - At this belated stage where the documents are not available with the department and this thing has been repeatedly coming on record and that the duty was paid under protest, the party is entitled to relief and matter remanded to Commissioner (Appeals) to allow the benefit of the Notification sought by the party after due examination of the same, as per law specially provisions of Section 149.- AT
Refund - Failure of the authority of pass fresh de-novo order in remand proceedings - At this belated stage where the documents are not available with the department and this thing has been repeatedly coming on record and that the duty was paid under protest, the party is entitled to relief and matter remanded to Commissioner (Appeals) to allow the benefit of the Notification sought by the party after due examination of the same, as per law specially provisions of Section 149.- AT
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