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 remanded the case to CIT(A) for substantive appeal adjudication after finding prima facie evidence suggesting the assessee's income was below taxable threshold. The tribunal noted documentary proof from school authorities and local tehsildar indicating potential agricultural land sale without capital gains tax liability. While advance tax payment under sections 208 and 210 remains the assessee's responsibility, the tribunal determined that the presented documents warrant further verification. Appeal was allowed for statistical purposes, directing CIT(A) to admit and examine the appeal on merits based on the submitted grounds in Form No. 35.
ITAT remanded the case to CIT(A) for substantive appeal adjudication after finding prima facie evidence suggesting the assessee's income was below taxable threshold. The tribunal noted documentary proof from school authorities and local tehsildar indicating potential agricultural land sale without capital gains tax liability. While advance tax payment under sections 208 and 210 remains the assessee's responsibility, the tribunal determined that the presented documents warrant further verification. Appeal was allowed for statistical purposes, directing CIT(A) to admit and examine the appeal on merits based on the submitted grounds in Form No. 35.
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