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 in filing the appeal - delay of 326 days - sufficient cause - After considering the arguments and perusing the materials, the Tribunal found that the delay was attributable to the actions of the former Tax Consultant and accepted the reasons provided by the assessee as sufficient cause for the delay. The Tribunal cited precedents emphasizing the need to decide appeals on merits rather than dismissing them on technical grounds unless there is gross negligence or mala fide intention.
Condonation of delay in filing the appeal - delay of 326 days - sufficient cause - After considering the arguments and perusing the materials, the Tribunal found that the delay was attributable to the actions of the former Tax Consultant and accepted the reasons provided by the assessee as sufficient cause for the delay. The Tribunal cited precedents emphasizing the need to decide appeals on merits rather than dismissing them on technical grounds unless there is gross negligence or mala fide intention.
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