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 set aside CIT(A)'s order regarding addition under s.69A for unexplained cash deposits. CIT(A) failed to fulfill statutory obligations under s.250(6) by not providing reasoned determination of appeal points and merely noting assessee's non-compliance with notices. The dismissal lacked merit-based adjudication and proper examination of appeal grounds. Additionally, while advance tax payment was required under s.249(4), CIT(A) neither specified the payable amount nor considered that assessee could seek exemption. Matter remanded for fresh consideration with directions to allow assessee to file advance tax exemption application. CIT(A) directed to pass speaking order addressing merits and grounds raised, following established precedents requiring substantive adjudication of appeals.
ITAT set aside CIT(A)'s order regarding addition under s.69A for unexplained cash deposits. CIT(A) failed to fulfill statutory obligations under s.250(6) by not providing reasoned determination of appeal points and merely noting assessee's non-compliance with notices. The dismissal lacked merit-based adjudication and proper examination of appeal grounds. Additionally, while advance tax payment was required under s.249(4), CIT(A) neither specified the payable amount nor considered that assessee could seek exemption. Matter remanded for fresh consideration with directions to allow assessee to file advance tax exemption application. CIT(A) directed to pass speaking order addressing merits and grounds raised, following established precedents requiring substantive adjudication of appeals.
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