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 holds that the CIT(A) erred in issuing a part order on jurisdictional points while leaving the assessee's substantive grounds undecided and directs a single consolidated adjudication. Treating section 250(6) of the I.T. Act as directory, the Tribunal notes the statutory expectation that the CIT(A) determine all points in one order within the prescribed timeframe. Applying section 251(1)(a), and given the assessment was framed under s.143(3), the CIT(A) was not obliged to await any collateral annulment question before confirming, reducing or enhancing the assessment. The matter is remitted to the CIT(A) to decide all grounds in the appeal by one consolidated order; appeal disposed accordingly.
ITAT holds that the CIT(A) erred in issuing a part order on jurisdictional points while leaving the assessee's substantive grounds undecided and directs a single consolidated adjudication. Treating section 250(6) of the I.T. Act as directory, the Tribunal notes the statutory expectation that the CIT(A) determine all points in one order within the prescribed timeframe. Applying section 251(1)(a), and given the assessment was framed under s.143(3), the CIT(A) was not obliged to await any collateral annulment question before confirming, reducing or enhancing the assessment. The matter is remitted to the CIT(A) to decide all grounds in the appeal by one consolidated order; appeal disposed accordingly.
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