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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Condonation of delay of 5318 days in filing the appeal - The reasons set out in the affidavit filed in support of the petition to condone the delay of 5318 days i.e., nearly 14 years are unconvincing and do not furnish any cause much less "sufficient cause" for condoning the delay in filing the appeal, instead reveal a callous attitude and a casual approach in availing the right of appeal. - HC
Condonation of delay of 5318 days in filing the appeal - The reasons set out in the affidavit filed in support of the petition to condone the delay of 5318 days i.e., nearly 14 years are unconvincing and do not furnish any cause much less "sufficient cause" for condoning the delay in filing the appeal, instead reveal a callous attitude and a casual approach in availing the right of appeal. - HC
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