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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Rejection of appeal on the ground of time limitation - whether the appellate authority had power to condone a delay of thirty days over and above the prescribed three month limitation period? - The High Court held that, the appellate authority cannot be faulted for rejecting the appeal. - However, the High Court condoned the delay on the ground that, the petitioner presented the appeal on 11.09.2023 and made the requisite pre-deposit. Apart from asserting that the petitioner was unaware about the show cause notice and assessment order, significantly, the petitioner has placed on record the death certificate of his mother. Matter restored back to appellate authority.
Rejection of appeal on the ground of time limitation - whether the appellate authority had power to condone a delay of thirty days over and above the prescribed three month limitation period? - The High Court held that, the appellate authority cannot be faulted for rejecting the appeal. - However, the High Court condoned the delay on the ground that, the petitioner presented the appeal on 11.09.2023 and made the requisite pre-deposit. Apart from asserting that the petitioner was unaware about the show cause notice and assessment order, significantly, the petitioner has placed on record the death certificate of his mother. Matter restored back to appellate authority.
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