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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Restoration of the statutory appeal - The CESTAT had dismissed the appeal due to the petitioner's non-representation at a hearing and the failure to inform about pre-deposit compliance. The petitioner later sought restoration, asserting compliance, albeit with a delay. - The High Court, noting the compliance with the pre-deposit requirement and the larger interest of justice, directed the restoration of the appeal on the CESTAT's board, subject to the petitioner depositing costs of INR 2 lakhs within two weeks.
Restoration of the statutory appeal - The CESTAT had dismissed the appeal due to the petitioner's non-representation at a hearing and the failure to inform about pre-deposit compliance. The petitioner later sought restoration, asserting compliance, albeit with a delay. - The High Court, noting the compliance with the pre-deposit requirement and the larger interest of justice, directed the restoration of the appeal on the CESTAT's board, subject to the petitioner depositing costs of INR 2 lakhs within two weeks.
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