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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ITAT condoned a 7-month delay in filing appeal before CIT(A), prioritizing substantial justice over technical considerations. Following precedent that meritorious matters should not be dismissed solely due to non-deliberate delays, the Tribunal determined that hearing the case on merits would better serve justice than rejecting it on procedural grounds. The matter was remitted back to CIT(A) for fresh adjudication on merits with directions to provide adequate hearing opportunity to the assessee. The delay was condoned considering that procedural lapses should not override substantive justice, particularly when the delay was not deliberate and the opposing party had no vested right in technical rejection.
ITAT condoned a 7-month delay in filing appeal before CIT(A), prioritizing substantial justice over technical considerations. Following precedent that meritorious matters should not be dismissed solely due to non-deliberate delays, the Tribunal determined that hearing the case on merits would better serve justice than rejecting it on procedural grounds. The matter was remitted back to CIT(A) for fresh adjudication on merits with directions to provide adequate hearing opportunity to the assessee. The delay was condoned considering that procedural lapses should not override substantive justice, particularly when the delay was not deliberate and the opposing party had no vested right in technical rejection.
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