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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The AT dismissed both review applications. The review by the appellant was held meritless because the impugned findings constituted an appreciation of materials on record by a co-ordinate bench and did not disclose any error apparent on the face of the record; such factual findings are not reversible in review. The regulator's review was likewise dismissed as hyper-technical, the WTM and AO having adjudicated on the same factual matrix, and no prima facie error warranting review was demonstrated. The Tribunal noted that the AO's orders have been set aside and remitted for fresh disposal, but declined to entertain either review, ordering both applications dismissed.
The AT dismissed both review applications. The review by the appellant was held meritless because the impugned findings constituted an appreciation of materials on record by a co-ordinate bench and did not disclose any error apparent on the face of the record; such factual findings are not reversible in review. The regulator's review was likewise dismissed as hyper-technical, the WTM and AO having adjudicated on the same factual matrix, and no prima facie error warranting review was demonstrated. The Tribunal noted that the AO's orders have been set aside and remitted for fresh disposal, but declined to entertain either review, ordering both applications dismissed.
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