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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The ITAT addressed the maintainability of an appeal under section 249(4), finding that the assessee's income was exempt from tax, rendering advance tax payment inapplicable. The tribunal held that dismissing the appeal on procedural grounds was unsustainable, given the assessee's exemption status. Regarding unexplained cash credit and denial of exemption under section 80P, the matter was remitted to the CIT(A) for fresh consideration. The appeal was partly allowed for statistical purposes, with the tribunal directing a comprehensive re-examination of the substantive issues by the lower appellate authority.
The ITAT addressed the maintainability of an appeal under section 249(4), finding that the assessee's income was exempt from tax, rendering advance tax payment inapplicable. The tribunal held that dismissing the appeal on procedural grounds was unsustainable, given the assessee's exemption status. Regarding unexplained cash credit and denial of exemption under section 80P, the matter was remitted to the CIT(A) for fresh consideration. The appeal was partly allowed for statistical purposes, with the tribunal directing a comprehensive re-examination of the substantive issues by the lower appellate authority.
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