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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Appellant's appeal before ITAT is dismissed for non-admission due to inordinate delay of 2,121 days; condonation of delay is refused for want of "sufficient cause" and bona fides. Tribunal found the appeal was prosecuted to exploit process of law after multiple earlier adjudications (AO, CIT(A), Coordinate Bench) concerning alleged bogus purchases where AO had made limited additions and earlier appellate fora rejected genuineness/identity. The Tribunal held equitable pleas of liberal or justice-oriented approach cannot override statutory limitation; public-policy underpinning of limitation bars revival of stale matters. Consequently, appeal is rejected purely on limitation grounds and is not admitted for adjudication.
Appellant's appeal before ITAT is dismissed for non-admission due to inordinate delay of 2,121 days; condonation of delay is refused for want of "sufficient cause" and bona fides. Tribunal found the appeal was prosecuted to exploit process of law after multiple earlier adjudications (AO, CIT(A), Coordinate Bench) concerning alleged bogus purchases where AO had made limited additions and earlier appellate fora rejected genuineness/identity. The Tribunal held equitable pleas of liberal or justice-oriented approach cannot override statutory limitation; public-policy underpinning of limitation bars revival of stale matters. Consequently, appeal is rejected purely on limitation grounds and is not admitted for adjudication.
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