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 notices issued unsigned - maintainability of writ petition against this issue in HC - The Court noted the petitioner's failure to file objections or comply with the procedure outlined in the aforementioned Supreme Court judgment. It emphasized that the petitioner should have first filed a return of income, sought reasons for the notice, and then filed objections. The Court criticized the petitioner for not following the prescribed procedure before approaching the Court directly. It suggested that the petitioner should have raised the issue of the unsigned notice in its earlier communications with the Department.
Validity of Reassessment notices issued unsigned - maintainability of writ petition against this issue in HC - The Court noted the petitioner's failure to file objections or comply with the procedure outlined in the aforementioned Supreme Court judgment. It emphasized that the petitioner should have first filed a return of income, sought reasons for the notice, and then filed objections. The Court criticized the petitioner for not following the prescribed procedure before approaching the Court directly. It suggested that the petitioner should have raised the issue of the unsigned notice in its earlier communications with the Department.
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