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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The Appellate Tribunal addressed the rejection of registration application u/s 12A/12AB due to a clerical error in selecting the appropriate section in the e-filing portal. The Tribunal found the error to be inadvertent and allowed correction in the application. The Tribunal directed the authority to consider the application under the correct sub-clause of section 12A(1) and to assess the case on merit. The delay in filing the application for approval u/s 80G(5) was also addressed, citing a recent CBDT circular extending the deadline. The Tribunal granted the assessee the benefit of the extended period for filing the application. The appeal was allowed for statistical purposes.
The Appellate Tribunal addressed the rejection of registration application u/s 12A/12AB due to a clerical error in selecting the appropriate section in the e-filing portal. The Tribunal found the error to be inadvertent and allowed correction in the application. The Tribunal directed the authority to consider the application under the correct sub-clause of section 12A(1) and to assess the case on merit. The delay in filing the application for approval u/s 80G(5) was also addressed, citing a recent CBDT circular extending the deadline. The Tribunal granted the assessee the benefit of the extended period for filing the application. The appeal was allowed for statistical purposes.
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