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 dismissed appellant's appeal challenging ITAT's rejection of delay condonation. Despite liberal interpretation of procedural delays, the court affirmed ITAT's findings that the seven-year delay demonstrated gross negligence and lack of bonafides. The appellant failed to demonstrate sufficient cause for such extensive delay, attempting to shift responsibility to legal counsel. The court held that while minor procedural delays may be excused, prolonged delays of years require stringent scrutiny. The ITAT's order was upheld, emphasizing the assessee's duty to diligently monitor legal proceedings and timely file appeals.
HC dismissed appellant's appeal challenging ITAT's rejection of delay condonation. Despite liberal interpretation of procedural delays, the court affirmed ITAT's findings that the seven-year delay demonstrated gross negligence and lack of bonafides. The appellant failed to demonstrate sufficient cause for such extensive delay, attempting to shift responsibility to legal counsel. The court held that while minor procedural delays may be excused, prolonged delays of years require stringent scrutiny. The ITAT's order was upheld, emphasizing the assessee's duty to diligently monitor legal proceedings and timely file appeals.
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