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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Section 144 empowers the Assessing Officer to proceed with best judgment assessment if the assessee fails to file return. Petitioner appeared through counsel but did not pursue further. AO invoked Section 144 and made assessment on best judgment basis in petitioner's absence. Court held AO's action valid and did not interfere, answering in favor of revenue. Authorities below did not violate Section 145.
Section 144 empowers the Assessing Officer to proceed with best judgment assessment if the assessee fails to file return. Petitioner appeared through counsel but did not pursue further. AO invoked Section 144 and made assessment on best judgment basis in petitioner's absence. Court held AO's action valid and did not interfere, answering in favor of revenue. Authorities below did not violate Section 145.
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