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 issues including best judgment assessment u/s 143(3) and eligibility for exemption u/ss 11/12. The Tribunal noted the lack of documentary evidence and non-compliance by the assessee despite notices. The assessee raised fresh grounds on the applicability of section 12AA and cited CBDT Circular No. 01/2015 regarding the retrospective operation of the first proviso to section 12A(2). The Tribunal found the AO did not consider this issue during assessment and remanded the matter for a fresh assessment. The appeal of the assessee was allowed for statistical purposes.
The Appellate Tribunal addressed issues including best judgment assessment u/s 143(3) and eligibility for exemption u/ss 11/12. The Tribunal noted the lack of documentary evidence and non-compliance by the assessee despite notices. The assessee raised fresh grounds on the applicability of section 12AA and cited CBDT Circular No. 01/2015 regarding the retrospective operation of the first proviso to section 12A(2). The Tribunal found the AO did not consider this issue during assessment and remanded the matter for a fresh assessment. The appeal of the assessee was allowed for statistical purposes.
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