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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Section 12AB(4) cancellation for specified violation is stated to operate prospectively from 01.04.2022, so a cancellation based on alleged breaches from FY 2014-15 was treated as retrospective application not permitted by the statute. The text further notes that reliance on section 12AA after its omission from 01.04.2021 was inconsistent with the statutory framework, and jurisdiction under section 12AB(4) could not arise without a specified violation after 01.04.2022. On merits, the alleged expenses were said to support religious and charitable objects, while valuation issues, accounting lapses and procedural defects did not establish non-genuineness or false information. The cancellation was therefore described as unsustainable.
Section 12AB(4) cancellation for specified violation is stated to operate prospectively from 01.04.2022, so a cancellation based on alleged breaches from FY 2014-15 was treated as retrospective application not permitted by the statute. The text further notes that reliance on section 12AA after its omission from 01.04.2021 was inconsistent with the statutory framework, and jurisdiction under section 12AB(4) could not arise without a specified violation after 01.04.2022. On merits, the alleged expenses were said to support religious and charitable objects, while valuation issues, accounting lapses and procedural defects did not establish non-genuineness or false information. The cancellation was therefore described as unsustainable.
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