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 addressed disallowance of exemption under s54B where appellant failed to submit required documentation to CIT(A)/NFAC despite multiple notices. While notices were sent to appellant's CA's email, who failed to inform appellant, resulting in appeal dismissal for non-prosecution. ITAT, considering overall circumstances and interests of justice, remanded matter back to CIT(A)/NFAC with directions to grant appellant final opportunity to substantiate claim with requisite details. CIT(A)/NFAC directed to adjudicate based on facts and law after appellant's submission. Appeal allowed for statistical purposes, contingent on appellant's compliance with submission requirements on appointed date.
ITAT addressed disallowance of exemption under s54B where appellant failed to submit required documentation to CIT(A)/NFAC despite multiple notices. While notices were sent to appellant's CA's email, who failed to inform appellant, resulting in appeal dismissal for non-prosecution. ITAT, considering overall circumstances and interests of justice, remanded matter back to CIT(A)/NFAC with directions to grant appellant final opportunity to substantiate claim with requisite details. CIT(A)/NFAC directed to adjudicate based on facts and law after appellant's submission. Appeal allowed for statistical purposes, contingent on appellant's compliance with submission requirements on appointed date.
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