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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The dominant issue was whether the appellate order under s.250 was vitiated for breach of natural justice due to denial of a requested personal hearing through video conferencing under the Faceless Appeal Scheme, 2021. Since the record showed that a specific request for such hearing was made via the National Faceless Appeal Centre but no hearing was granted, the order was treated as procedurally infirm. The appeal was restored to the first appellate authority for de novo adjudication after granting an opportunity of personal hearing in accordance with the Scheme, with liberty to make a fresh request under the relevant clause. - ITAT
The dominant issue was whether the appellate order under s.250 was vitiated for breach of natural justice due to denial of a requested personal hearing through video conferencing under the Faceless Appeal Scheme, 2021. Since the record showed that a specific request for such hearing was made via the National Faceless Appeal Centre but no hearing was granted, the order was treated as procedurally infirm. The appeal was restored to the first appellate authority for de novo adjudication after granting an opportunity of personal hearing in accordance with the Scheme, with liberty to make a fresh request under the relevant clause. - ITAT
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