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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Validity of reassessment proceedings - non-service of notice u/s 148A(b) through e-mail - Denial of principle of natural justice - The High Court examined the evidence and found that the notice was effectively served at the petitioner's registered address, meeting the requirements of natural justice. As there was no rebuttal to the respondent's evidence, the Court upheld the validity of the notice and dismissed the petitioner's challenge. The Court also noted that the petitioner had alternative remedies available to address the assessment order.
Validity of reassessment proceedings - non-service of notice u/s 148A(b) through e-mail - Denial of principle of natural justice - The High Court examined the evidence and found that the notice was effectively served at the petitioner's registered address, meeting the requirements of natural justice. As there was no rebuttal to the respondent's evidence, the Court upheld the validity of the notice and dismissed the petitioner's challenge. The Court also noted that the petitioner had alternative remedies available to address the assessment order.
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