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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The HC dismissed the writ petition challenging the rejection of an application under Section 264 of the Income Tax Act, 1961, holding that such orders are not appealable before the Tribunal under Section 253. The petitioner's sole remedy lies in filing an appeal under Section 246 against the intimation issued under Section 143(1). Noting a prima facie error in failing to file Form 67 as mandated by Rule 128, the court acknowledged the appellate Commissioner's authority under Section 249(3) to condone the delay in filing the appeal. Applying the Limitation Act's Section 14, the petitioner was granted relief for delay caused by pursuing an incorrect remedy. The petition was disposed of with a direction for the petitioner to file the appeal against the Section 143(1) intimation before the appellate Commissioner within 30 days of the order's receipt.
The HC dismissed the writ petition challenging the rejection of an application under Section 264 of the Income Tax Act, 1961, holding that such orders are not appealable before the Tribunal under Section 253. The petitioner's sole remedy lies in filing an appeal under Section 246 against the intimation issued under Section 143(1). Noting a prima facie error in failing to file Form 67 as mandated by Rule 128, the court acknowledged the appellate Commissioner's authority under Section 249(3) to condone the delay in filing the appeal. Applying the Limitation Act's Section 14, the petitioner was granted relief for delay caused by pursuing an incorrect remedy. The petition was disposed of with a direction for the petitioner to file the appeal against the Section 143(1) intimation before the appellate Commissioner within 30 days of the order's receipt.
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