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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Reassessment proceedings were ex-parte, violating principles of natural justice as petitioner was not provided reasonable opportunity to file reply documents due to notice u/s 148A(b) being delivered to inactive email id. Petitioner filed returns for other assessment years, but mistakenly believed income for AY 2018-19 was below exemption limit. Inability to reply was due to bona fide reasons and sufficient cause. Impugned notice, order violative of natural justice, quashed, matter remitted for fresh consideration in accordance with law.
Reassessment proceedings were ex-parte, violating principles of natural justice as petitioner was not provided reasonable opportunity to file reply documents due to notice u/s 148A(b) being delivered to inactive email id. Petitioner filed returns for other assessment years, but mistakenly believed income for AY 2018-19 was below exemption limit. Inability to reply was due to bona fide reasons and sufficient cause. Impugned notice, order violative of natural justice, quashed, matter remitted for fresh consideration in accordance with law.
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