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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Condonation of delay in filing an appeal to the ITAT was allowed by the High Court on the ground that a 202 day delay arose from COVID 19 disruption and consequent commercial paralysis, which prevented timely prosecution; this finding led the court to restore the appellant's right to have the ITAT decide the appeal on merits. The court noted the appellant's contention that the appellate order below was passed without oral hearing and, to balance fairness, granted restoration subject to a monetary condition; consequence: the delay was condoned but the appellant must pay Rs.15,000 to the State Legal Services Authority within 15 days as a cost.
Condonation of delay in filing an appeal to the ITAT was allowed by the High Court on the ground that a 202 day delay arose from COVID 19 disruption and consequent commercial paralysis, which prevented timely prosecution; this finding led the court to restore the appellant's right to have the ITAT decide the appeal on merits. The court noted the appellant's contention that the appellate order below was passed without oral hearing and, to balance fairness, granted restoration subject to a monetary condition; consequence: the delay was condoned but the appellant must pay Rs.15,000 to the State Legal Services Authority within 15 days as a cost.
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