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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Initiation of contempt proceedings by issuance of a show cause notice does not ordinarily create an appealable right because it does not adjudicate substantial rights; accordingly the appellate forum declined to entertain the appeal against the notice but granted liberty to the respondent to file a reply to the notice before the tribunal. An interim disclosure direction concerning transactions was treated as superseded and its subject matter subsumed in a pending substantive appeal, so the separate appeal on that disclosure was dismissed as unnecessary and related pending applications were disposed of.
Initiation of contempt proceedings by issuance of a show cause notice does not ordinarily create an appealable right because it does not adjudicate substantial rights; accordingly the appellate forum declined to entertain the appeal against the notice but granted liberty to the respondent to file a reply to the notice before the tribunal. An interim disclosure direction concerning transactions was treated as superseded and its subject matter subsumed in a pending substantive appeal, so the separate appeal on that disclosure was dismissed as unnecessary and related pending applications were disposed of.
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