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 SC set aside the HC's impugned orders and remitted the appeals to the HC for fresh adjudication on the raised questions of law, directing reconsideration in light of this Court's holding that s.80AB (with effect from 01-04-1981) governs the assessment years in issue and supports the revenue's stance that deductions under s.80I must be treated having regard to investment allowance/deposit claims under s.32AB. The SC instructed the HC to hear and finally decide the matters expeditiously, preferably within six months of receipt of the order. Parties are anonymized as appellant/assessee and revenue for purposes of further proceedings.
The SC set aside the HC's impugned orders and remitted the appeals to the HC for fresh adjudication on the raised questions of law, directing reconsideration in light of this Court's holding that s.80AB (with effect from 01-04-1981) governs the assessment years in issue and supports the revenue's stance that deductions under s.80I must be treated having regard to investment allowance/deposit claims under s.32AB. The SC instructed the HC to hear and finally decide the matters expeditiously, preferably within six months of receipt of the order. Parties are anonymized as appellant/assessee and revenue for purposes of further proceedings.
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