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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HC determined the ITAT's decision to remand the matter to CIT(A) was improper when the issue was purely legal under Rule 27. Given ITAT had acknowledged the legal nature of the dispute and the appellant's valid invocation of Rule 27, remanding would only prolong litigation through additional appeal rounds. The HC set aside ITAT's remand order, directing ITAT to adjudicate the merits itself. The ruling emphasizes judicial efficiency by avoiding unnecessary procedural delays when the tribunal has jurisdiction and capability to resolve the substantive legal questions directly.
HC determined the ITAT's decision to remand the matter to CIT(A) was improper when the issue was purely legal under Rule 27. Given ITAT had acknowledged the legal nature of the dispute and the appellant's valid invocation of Rule 27, remanding would only prolong litigation through additional appeal rounds. The HC set aside ITAT's remand order, directing ITAT to adjudicate the merits itself. The ruling emphasizes judicial efficiency by avoiding unnecessary procedural delays when the tribunal has jurisdiction and capability to resolve the substantive legal questions directly.
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