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 back to CIT(A) due to procedural irregularities in ex-parte order. The tribunal found that the CIT(A) failed to conduct proper deliberation on appeal merits and did not consider available material on record. The order was set aside, providing the assessee a final opportunity to present arguments before the first appellate authority. The tribunal's decision was consistent with precedent, emphasizing the need for substantive adjudication and fair hearing in tax appeal proceedings.
ITAT remanded the case back to CIT(A) due to procedural irregularities in ex-parte order. The tribunal found that the CIT(A) failed to conduct proper deliberation on appeal merits and did not consider available material on record. The order was set aside, providing the assessee a final opportunity to present arguments before the first appellate authority. The tribunal's decision was consistent with precedent, emphasizing the need for substantive adjudication and fair hearing in tax appeal proceedings.
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