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 refer stay petitions to the administrative Principal Commissioner/Commissioner under the CBDT Office Memorandum vitiated the assessing officer's stay rejection; the matter is remitted for the Principal Commissioner/Commissioner to determine the quantum or proportion of disputed demand payable for grant of stay in accordance with the guideline. The Department retains entitlement to recover assessed demand pending disposal of appeals subject to any statutory stay, the legal basis for recovery affirmed. In view of prior partial liquidation distributions, petitioners are permitted to operate previously attached bank accounts pending fresh administrative orders to be issued within the stipulated timeframe.
Failure to refer stay petitions to the administrative Principal Commissioner/Commissioner under the CBDT Office Memorandum vitiated the assessing officer's stay rejection; the matter is remitted for the Principal Commissioner/Commissioner to determine the quantum or proportion of disputed demand payable for grant of stay in accordance with the guideline. The Department retains entitlement to recover assessed demand pending disposal of appeals subject to any statutory stay, the legal basis for recovery affirmed. In view of prior partial liquidation distributions, petitioners are permitted to operate previously attached bank accounts pending fresh administrative orders to be issued within the stipulated timeframe.
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