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 adjudicated a tax exemption dispute under Section 10(26) regarding income from scheduled areas. The tribunal found that the lower appellate authority (CIT(A)) did not provide adequate opportunity for the assessee to substantiate the exemption claim. Consequently, the ITAT set aside the previous order and remanded the case for de novo proceedings. The tribunal directed the CIT(A) to: 1. Reconsider the assessee's submissions 2. Provide reasonable opportunity for hearing 3. Allow the assessee to explain the exemption claim All appeal grounds were allowed for statistical purposes, mandating a fresh evaluation of the tax exemption status.
ITAT adjudicated a tax exemption dispute under Section 10(26) regarding income from scheduled areas. The tribunal found that the lower appellate authority (CIT(A)) did not provide adequate opportunity for the assessee to substantiate the exemption claim. Consequently, the ITAT set aside the previous order and remanded the case for de novo proceedings. The tribunal directed the CIT(A) to: 1. Reconsider the assessee's submissions 2. Provide reasonable opportunity for hearing 3. Allow the assessee to explain the exemption claim All appeal grounds were allowed for statistical purposes, mandating a fresh evaluation of the tax exemption status.
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