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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Quashing of ex parte assessment order and remand for fresh adjudication on merits subject to a pre-deposit regime is directed; HC requires the assessee to deposit between 25% and 100% of disputed tax depending on delay, with the present case requiring one-third as pre-deposit, and mandates vacation of bank attachment upon compliance. Prior payments or recoveries shall be set off against the pre-deposit. Failure to comply permits the revenue to resume recovery proceedings as if the petition were dismissed. Writ petition disposed accordingly.
Quashing of ex parte assessment order and remand for fresh adjudication on merits subject to a pre-deposit regime is directed; HC requires the assessee to deposit between 25% and 100% of disputed tax depending on delay, with the present case requiring one-third as pre-deposit, and mandates vacation of bank attachment upon compliance. Prior payments or recoveries shall be set off against the pre-deposit. Failure to comply permits the revenue to resume recovery proceedings as if the petition were dismissed. Writ petition disposed accordingly.
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