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 set aside the impugned assessment order under s.143(3) r.w.s.144C(3) and remitted the matter to DRP. While petitioner filed objections to draft order with DRP, they failed to notify the assessing officer, leading to final assessment issuance. Though AO was not at fault, considering similar precedent circumstances, court exercised discretion to grant additional opportunity. However, due to petitioner's procedural lapse in not informing AO about pending DRP objections, costs of Rs.10,000 were imposed payable to HC employees medical welfare fund. Court emphasized this discretionary relief was case-specific based on peculiar facts and not a general precedent.
HC set aside the impugned assessment order under s.143(3) r.w.s.144C(3) and remitted the matter to DRP. While petitioner filed objections to draft order with DRP, they failed to notify the assessing officer, leading to final assessment issuance. Though AO was not at fault, considering similar precedent circumstances, court exercised discretion to grant additional opportunity. However, due to petitioner's procedural lapse in not informing AO about pending DRP objections, costs of Rs.10,000 were imposed payable to HC employees medical welfare fund. Court emphasized this discretionary relief was case-specific based on peculiar facts and not a general precedent.
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