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 upheld the Tribunal's refusal to rectify the assessment under s.254(2), concluding the Tribunal's power is confined to correcting mistakes apparent on the record and does not extend to rehearing or reviewing its own decision. No mistake apparent from the record was shown; the assessment dated 24.12.2007, issued after the Appellant's 2005 return and following non-compliance with multiple AO notices, did not cause demonstrable prejudice. The Tribunal and CIT(A) afforded full opportunity to be heard, considered merits across three rounds of litigation, and dismissed the rectification application. Given the Appellant's failure to challenge the Tribunal's 31.10.2019 order on merits, HC declined further relief and dismissed the challenge.
HC upheld the Tribunal's refusal to rectify the assessment under s.254(2), concluding the Tribunal's power is confined to correcting mistakes apparent on the record and does not extend to rehearing or reviewing its own decision. No mistake apparent from the record was shown; the assessment dated 24.12.2007, issued after the Appellant's 2005 return and following non-compliance with multiple AO notices, did not cause demonstrable prejudice. The Tribunal and CIT(A) afforded full opportunity to be heard, considered merits across three rounds of litigation, and dismissed the rectification application. Given the Appellant's failure to challenge the Tribunal's 31.10.2019 order on merits, HC declined further relief and dismissed the challenge.
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