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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Revision application filed u/s 264 - Upon perusal of the documents, the High Court noted that the matter was not heard and decided on the initial date, and no notice was given to the petitioner for the subsequent date. The court opines that the officer should have granted another opportunity to the petitioner to appear and present their case before passing an adverse order. The failure to do so constitutes a violation of principles of natural justice. Accordingly, the HC directed the PCIT to re-consider the matter.
Revision application filed u/s 264 - Upon perusal of the documents, the High Court noted that the matter was not heard and decided on the initial date, and no notice was given to the petitioner for the subsequent date. The court opines that the officer should have granted another opportunity to the petitioner to appear and present their case before passing an adverse order. The failure to do so constitutes a violation of principles of natural justice. Accordingly, the HC directed the PCIT to re-consider the matter.
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