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 ITAT set aside the Ld. CIT(A)'s legal finding in favour of the assessee because the assessee failed to raise the objection mandated by s.124. The matter is remitted to the CIT(A) for fresh adjudication on the merits, directing that the appeal be decided after considering the assessee's submissions and material and after affording a reasonable opportunity of hearing; the assessee is directed to cooperate for expeditious disposal. Procedurally, the tribunal dismissed Revenue's grounds 2-7 and allowed ground 1. The tribunal's order requires the CIT(A) to re-evaluate jurisdictional and transfer-related issues in light of applicable statutory provisions during the rehearing.
The ITAT set aside the Ld. CIT(A)'s legal finding in favour of the assessee because the assessee failed to raise the objection mandated by s.124. The matter is remitted to the CIT(A) for fresh adjudication on the merits, directing that the appeal be decided after considering the assessee's submissions and material and after affording a reasonable opportunity of hearing; the assessee is directed to cooperate for expeditious disposal. Procedurally, the tribunal dismissed Revenue's grounds 2-7 and allowed ground 1. The tribunal's order requires the CIT(A) to re-evaluate jurisdictional and transfer-related issues in light of applicable statutory provisions during the rehearing.
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