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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SC remanded the matter to HC, directing expedited review of an ex-parte assessment reopening order. The court mandated HC to adjudicate the pending review petition within four weeks, preserving the petitioner's right to seek alternative legal remedies if the outcome is unfavorable. The decision emphasizes procedural fairness by allowing the petitioner an opportunity to challenge the original ex-parte order regarding tax assessment exemption under Sections 11 and 12, while maintaining judicial economy through time-bound resolution.
SC remanded the matter to HC, directing expedited review of an ex-parte assessment reopening order. The court mandated HC to adjudicate the pending review petition within four weeks, preserving the petitioner's right to seek alternative legal remedies if the outcome is unfavorable. The decision emphasizes procedural fairness by allowing the petitioner an opportunity to challenge the original ex-parte order regarding tax assessment exemption under Sections 11 and 12, while maintaining judicial economy through time-bound resolution.
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