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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Petitioner's refund claim was remitted to the Principal Chief Commissioner of Income Tax West Bengal & Sikkim to nominate a competent officer (Commissioner rank or above) to conduct an enquiry and decide the refund claim in accordance with law; the officer must issue notice to the petitioner within one week and hear its case. The court directed that if the petitioner is entitled to a refund it must not be denied, while emphasising the petitioner's obligation to maintain supporting documents and the department's responsibility to consider available records. Affidavits were not ordered.
Petitioner's refund claim was remitted to the Principal Chief Commissioner of Income Tax West Bengal & Sikkim to nominate a competent officer (Commissioner rank or above) to conduct an enquiry and decide the refund claim in accordance with law; the officer must issue notice to the petitioner within one week and hear its case. The court directed that if the petitioner is entitled to a refund it must not be denied, while emphasising the petitioner's obligation to maintain supporting documents and the department's responsibility to consider available records. Affidavits were not ordered.
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