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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Failure to record reasons in an administrative decision was held to violate principles of natural justice because the competent bodies did not disclose why the petitioner's submissions or parity claims were rejected; administrative orders must state reasons objectively and cannot be supplemented after the fact. In view of the absence of adequate reasoning and apparent non application of mind, the matter is remitted to the Review Committee for fresh consideration and for passing a reasoned order addressing the contentions and parity issues within a reasonable time.
Failure to record reasons in an administrative decision was held to violate principles of natural justice because the competent bodies did not disclose why the petitioner's submissions or parity claims were rejected; administrative orders must state reasons objectively and cannot be supplemented after the fact. In view of the absence of adequate reasoning and apparent non application of mind, the matter is remitted to the Review Committee for fresh consideration and for passing a reasoned order addressing the contentions and parity issues within a reasonable time.
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