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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The respondent passed an order u/s 148A(d) and issued a consequential notice u/s 148 based on information gathered during a surprise check conducted by enforcement officials, relating to documents produced by the petitioner in support of their case when filing a reply. The petitioner claimed violation of Section 148A(b) and principles of natural justice, as the order/notice pertained to an issue not covered by the two show cause notices. However, the court held that the respondent acted based on irregularities found in the documents submitted by the petitioner during scrutiny of their replies. The petitioner was directed to file returns u/s 148, and if aggrieved, could file a reply to the notice. The court found no merit in the petitioner's contention.
The respondent passed an order u/s 148A(d) and issued a consequential notice u/s 148 based on information gathered during a surprise check conducted by enforcement officials, relating to documents produced by the petitioner in support of their case when filing a reply. The petitioner claimed violation of Section 148A(b) and principles of natural justice, as the order/notice pertained to an issue not covered by the two show cause notices. However, the court held that the respondent acted based on irregularities found in the documents submitted by the petitioner during scrutiny of their replies. The petitioner was directed to file returns u/s 148, and if aggrieved, could file a reply to the notice. The court found no merit in the petitioner's contention.
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