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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Priority/out of turn hearing of the appeals pending with CsIT (AU) and/or CIT(A) - The judgment by the Madras High Court addressed the petitioner's grievance regarding the rejection of their appeal against an assessment order. Despite acknowledging the genuine hardship faced by the petitioner, the Court declined to prioritize their case due to the backlog of appeals before the Appellate Commissioner. Instead, it advised the petitioner to file an application for a stay of recovery proceedings, granting them four weeks to do so. The respondents were directed to suspend all recovery proceedings until the application is resolved.
Priority/out of turn hearing of the appeals pending with CsIT (AU) and/or CIT(A) - The judgment by the Madras High Court addressed the petitioner's grievance regarding the rejection of their appeal against an assessment order. Despite acknowledging the genuine hardship faced by the petitioner, the Court declined to prioritize their case due to the backlog of appeals before the Appellate Commissioner. Instead, it advised the petitioner to file an application for a stay of recovery proceedings, granting them four weeks to do so. The respondents were directed to suspend all recovery proceedings until the application is resolved.
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