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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Framing assessment u/s 143(3) without serving notices at the registered e-mail address - changing of the e-mail id - The ITAT found that the appellant had not communicated their change in email address to the revenue authorities, hence dismissing the appellant's claim of non-service of notices. - Concerning the disallowance of exceptional items, the tribunal determined that the shares issued by RFCL to the appellant constituted income, earned in exchange for the right to use the appellant's capital asset. Therefore, the disallowance made by the Assessing Officer was upheld. The tribunal directed the deletion of any income already offered for taxation in subsequent years to avoid double taxation.
Framing assessment u/s 143(3) without serving notices at the registered e-mail address - changing of the e-mail id - The ITAT found that the appellant had not communicated their change in email address to the revenue authorities, hence dismissing the appellant's claim of non-service of notices. - Concerning the disallowance of exceptional items, the tribunal determined that the shares issued by RFCL to the appellant constituted income, earned in exchange for the right to use the appellant's capital asset. Therefore, the disallowance made by the Assessing Officer was upheld. The tribunal directed the deletion of any income already offered for taxation in subsequent years to avoid double taxation.
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