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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Challenge to the validity of the SCN on the ground that it was issued by an incompetent officer was rejected because, though the portal reflected the Superintendent, the SCN was actually signed by the competent Joint Director; consequently, the SCN was not invalidated. Objection to appellate forum/jurisdiction was rejected as the correct appellate authority was the Commissioner (Appeals), and the impugned DRC-07 was only a portal summary uploaded by the jurisdictional commissionerate based on the highest tax-demand principle in multi-notice adjudications; consequently, the petitioner was relegated to the statutory appeal, with a direction that an appeal filed by 31-01-2026 with pre-deposit shall not be dismissed as time-barred and must be decided on merits. - HC
Challenge to the validity of the SCN on the ground that it was issued by an incompetent officer was rejected because, though the portal reflected the Superintendent, the SCN was actually signed by the competent Joint Director; consequently, the SCN was not invalidated. Objection to appellate forum/jurisdiction was rejected as the correct appellate authority was the Commissioner (Appeals), and the impugned DRC-07 was only a portal summary uploaded by the jurisdictional commissionerate based on the highest tax-demand principle in multi-notice adjudications; consequently, the petitioner was relegated to the statutory appeal, with a direction that an appeal filed by 31-01-2026 with pre-deposit shall not be dismissed as time-barred and must be decided on merits. - HC
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