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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Validity of electronically issued assessment orders was contested for absence of a DIN and unsigned show cause notices; the HC recorded that the assessment carried a portal-generated Reference No (auto-assigned and exclusive to that assessment) and rejected the challenge to electronic issuance on that basis. The HC also found the petitioner aware of assessment action and unable to explain delay between appeal rejection and writ filing; on the ground of laches the writ petition was dismissed. No substantive grounds raised in the petition were sustained.
Validity of electronically issued assessment orders was contested for absence of a DIN and unsigned show cause notices; the HC recorded that the assessment carried a portal-generated Reference No (auto-assigned and exclusive to that assessment) and rejected the challenge to electronic issuance on that basis. The HC also found the petitioner aware of assessment action and unable to explain delay between appeal rejection and writ filing; on the ground of laches the writ petition was dismissed. No substantive grounds raised in the petition were sustained.
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