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 held that cross-objections are not maintainable under Section 260A of the Act absent specific statutory recognition, unlike Section 253(4). A respondent's right under Section 260A(6)(b) is limited to advancing contentions on adverse Tribunal findings only if they are intrinsically connected to the substantial question of law in the admitted appeal. The provision is merely enabling and does not confer an independent right to raise challenges disconnected from the admitted question. While respondents may support ultimate decisions by pressing connected issues decided against them without separate cross-objections, they must pursue appropriate appellate remedies for unconnected grievances rather than filing cross-objections.
HC held that cross-objections are not maintainable under Section 260A of the Act absent specific statutory recognition, unlike Section 253(4). A respondent's right under Section 260A(6)(b) is limited to advancing contentions on adverse Tribunal findings only if they are intrinsically connected to the substantial question of law in the admitted appeal. The provision is merely enabling and does not confer an independent right to raise challenges disconnected from the admitted question. While respondents may support ultimate decisions by pressing connected issues decided against them without separate cross-objections, they must pursue appropriate appellate remedies for unconnected grievances rather than filing cross-objections.
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