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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Condonation of delay in filing appeal before CIT(A) granted despite delay of 1000 to 2000 days, as substantial justice prevails over technical considerations. Excessive or inordinate delay irrelevant when reasonable cause exists. Reliance placed on precedents condoning delays up to 21 years. TDS u/s 194C computed on year-end figures from Receipt & Payment account incorrect; remitted to AO for fresh examination of each payment's TDS applicability. Assessee directed to update contact details, provide necessary documents, and cooperate; failure may lead to denial of leniency. Appeals allowed for statistical purposes.
Condonation of delay in filing appeal before CIT(A) granted despite delay of 1000 to 2000 days, as substantial justice prevails over technical considerations. Excessive or inordinate delay irrelevant when reasonable cause exists. Reliance placed on precedents condoning delays up to 21 years. TDS u/s 194C computed on year-end figures from Receipt & Payment account incorrect; remitted to AO for fresh examination of each payment's TDS applicability. Assessee directed to update contact details, provide necessary documents, and cooperate; failure may lead to denial of leniency. Appeals allowed for statistical purposes.
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