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 allowed writ petition under Article 226, finding procedural infirmities in the assessment process. The court held that Respondent No.1 failed to consider a supplier's timely reply to the s.133(6) notice and supporting documents, and relied on non-existent judicial precedents when computing peak director-loan balances without disclosing basis or issuing a show cause notice. The HC remanded the matter to the Assessing Officer for fresh adjudication, directing issuance of a fresh show cause notice specifying proposed additions and disallowances, provision of reasonable time and opportunity to file replies, and mandatory personal hearing before passing the assessment order.
HC allowed writ petition under Article 226, finding procedural infirmities in the assessment process. The court held that Respondent No.1 failed to consider a supplier's timely reply to the s.133(6) notice and supporting documents, and relied on non-existent judicial precedents when computing peak director-loan balances without disclosing basis or issuing a show cause notice. The HC remanded the matter to the Assessing Officer for fresh adjudication, directing issuance of a fresh show cause notice specifying proposed additions and disallowances, provision of reasonable time and opportunity to file replies, and mandatory personal hearing before passing the assessment order.
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