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 set aside the impugned order rejecting the assessee's application for registration under section 12AB, concluding the rejection was based on a procedural/clerical misdescription of the provision in Form 10A and was effected without affording an opportunity to rectify. The Tribunal held that procedural lapses should not defeat substantive entitlement where the assessee is otherwise eligible and that denial without opportunity to cure violates principles of natural justice. The matter is remitted to the file of the CIT(E) with a direction to admit the application and adjudicate the registration claim on merits after affording the assessee a chance to rectify the defect.
ITAT set aside the impugned order rejecting the assessee's application for registration under section 12AB, concluding the rejection was based on a procedural/clerical misdescription of the provision in Form 10A and was effected without affording an opportunity to rectify. The Tribunal held that procedural lapses should not defeat substantive entitlement where the assessee is otherwise eligible and that denial without opportunity to cure violates principles of natural justice. The matter is remitted to the file of the CIT(E) with a direction to admit the application and adjudicate the registration claim on merits after affording the assessee a chance to rectify the defect.
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