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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Impugned order suffers from non-application of mind, violation of principles of natural justice. Tribunal failed to consider grounds raised by petitioner for delay in filing rectification application. Coordinate Bench held Tribunal has jurisdiction to recall ex parte order, rehear matter. Petitioner claimed lack of communication regarding Tribunal's order, leading to delay. Impugned orders set aside, matter remitted to Tribunal to decide petitioner's application afresh in accordance with law. Revision allowed by way of remand.
Impugned order suffers from non-application of mind, violation of principles of natural justice. Tribunal failed to consider grounds raised by petitioner for delay in filing rectification application. Coordinate Bench held Tribunal has jurisdiction to recall ex parte order, rehear matter. Petitioner claimed lack of communication regarding Tribunal's order, leading to delay. Impugned orders set aside, matter remitted to Tribunal to decide petitioner's application afresh in accordance with law. Revision allowed by way of remand.
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