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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Where scrutiny assessment is completed through the e-proceedings mechanism, the prescribed procedure requires the Assessing Officer to sign the assessment order digitally. Because the assessment order in this case was admittedly passed through e-proceedings but was only manually signed, it did not conform to the binding procedure and the defect vitiated the assessment. The additional legal ground was therefore admitted, the assessment was quashed, and the remaining grounds were treated as academic.
Where scrutiny assessment is completed through the e-proceedings mechanism, the prescribed procedure requires the Assessing Officer to sign the assessment order digitally. Because the assessment order in this case was admittedly passed through e-proceedings but was only manually signed, it did not conform to the binding procedure and the defect vitiated the assessment. The additional legal ground was therefore admitted, the assessment was quashed, and the remaining grounds were treated as academic.
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