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 held that CIT(A) erred in invoking section 249(4)(b) to dismiss the assessee's appeals in limine on the ground of non-payment of advance tax computed on assessed income, including disputed additions. Relying on precedent, ITAT ruled that advance tax liability must be determined under sections 208 and 209 on admitted or undisputed income, not on contested additions, and that there was no admitted tax liability in this case. The impugned dismissal was set aside and the matter remanded to the AO for de novo adjudication, subject to the assessee depositing Rs. 70,000 within one month and being granted adequate opportunity of hearing.
ITAT held that CIT(A) erred in invoking section 249(4)(b) to dismiss the assessee's appeals in limine on the ground of non-payment of advance tax computed on assessed income, including disputed additions. Relying on precedent, ITAT ruled that advance tax liability must be determined under sections 208 and 209 on admitted or undisputed income, not on contested additions, and that there was no admitted tax liability in this case. The impugned dismissal was set aside and the matter remanded to the AO for de novo adjudication, subject to the assessee depositing Rs. 70,000 within one month and being granted adequate opportunity of hearing.
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