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 observed that the rejection of the assessee's applications for registration u/s 12AA and approval u/s 80G, premised on non-registration under the RPT and questioned genuineness of activities, could not be sustained without affording an opportunity to cure curable defects. Noting that RPT registration was in the finalization stage, the Tribunal held that a liberal approach is warranted, declined to decide merits, and remitted the matter to the assessing authority with a direction to afford the assessee an adequate opportunity of hearing and to permit submission of clarifications and documents to establish registration status and genuineness before passing a fresh decision.
ITAT observed that the rejection of the assessee's applications for registration u/s 12AA and approval u/s 80G, premised on non-registration under the RPT and questioned genuineness of activities, could not be sustained without affording an opportunity to cure curable defects. Noting that RPT registration was in the finalization stage, the Tribunal held that a liberal approach is warranted, declined to decide merits, and remitted the matter to the assessing authority with a direction to afford the assessee an adequate opportunity of hearing and to permit submission of clarifications and documents to establish registration status and genuineness before passing a fresh decision.
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