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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Revision application u/s 264 was initially rejected due to non-payment of mandatory fee of Rs. 500. However, the petitioner paid the fee immediately upon objection raised. The court held that the statutory requirement of Section 264(5) was sufficiently complied with by payment of fees, even if the filing date is considered as the date of fee payment. The decision relied upon by the respondent was inapplicable as no fees were paid in that case, whereas in the present case, fees were paid upon objection. The impugned order rejecting the revision application on technical grounds was quashed and the matter remanded to decide on merits after providing an opportunity of hearing within 12 weeks.
Revision application u/s 264 was initially rejected due to non-payment of mandatory fee of Rs. 500. However, the petitioner paid the fee immediately upon objection raised. The court held that the statutory requirement of Section 264(5) was sufficiently complied with by payment of fees, even if the filing date is considered as the date of fee payment. The decision relied upon by the respondent was inapplicable as no fees were paid in that case, whereas in the present case, fees were paid upon objection. The impugned order rejecting the revision application on technical grounds was quashed and the matter remanded to decide on merits after providing an opportunity of hearing within 12 weeks.
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