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 set aside appellate authority's order for violating principles of natural justice by passing cryptic, non-speaking order without addressing petitioners' grounds raised in appeal memos. Court held appellate authority failed to apply judicial mind, assign reasons, or deal with petitioners' defense regarding right to cross-examine witnesses. Authority merely stated petitioners failed to provide credible evidence without examining their submissions. Applying Kranti Associates precedent, HC found impugned order cannot sustain judicial scrutiny due to non-application of mind. Both appellate orders set aside; petitioners directed to appear before appellate authority for fresh hearing on specified date.
HC set aside appellate authority's order for violating principles of natural justice by passing cryptic, non-speaking order without addressing petitioners' grounds raised in appeal memos. Court held appellate authority failed to apply judicial mind, assign reasons, or deal with petitioners' defense regarding right to cross-examine witnesses. Authority merely stated petitioners failed to provide credible evidence without examining their submissions. Applying Kranti Associates precedent, HC found impugned order cannot sustain judicial scrutiny due to non-application of mind. Both appellate orders set aside; petitioners directed to appear before appellate authority for fresh hearing on specified date.
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