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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CIT(A) erred in rejecting assessee's delay condonation request on technical grounds without considering assessee's absence from India until order receipt date. Assessee filed appeal within 30 days of returning to India, satisfying Section 249(2)(b) requirement. CIT(A) adopted pedantic approach, ignoring sufficient cause. Matter remanded to AO to decide afresh after issuing notice to assessee's updated address and email, allowing submissions. Assessee's lack of opportunity before AO also noted.
CIT(A) erred in rejecting assessee's delay condonation request on technical grounds without considering assessee's absence from India until order receipt date. Assessee filed appeal within 30 days of returning to India, satisfying Section 249(2)(b) requirement. CIT(A) adopted pedantic approach, ignoring sufficient cause. Matter remanded to AO to decide afresh after issuing notice to assessee's updated address and email, allowing submissions. Assessee's lack of opportunity before AO also noted.
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