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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Penalties for alleged violations of cash loan and repayment restrictions were treated as consequential to the quantum assessments in which the underlying findings were recorded. Once the co-ordinate Bench had quashed the assessee's quantum assessments, the foundation for the penalty orders disappeared, and the penalties had no independent existence to survive. The Tribunal therefore deleted all the penalties for the years in appeal and rejected the request to keep the matters pending, while leaving the Department free to seek revival if it later succeeded in the quantum proceedings.
Penalties for alleged violations of cash loan and repayment restrictions were treated as consequential to the quantum assessments in which the underlying findings were recorded. Once the co-ordinate Bench had quashed the assessee's quantum assessments, the foundation for the penalty orders disappeared, and the penalties had no independent existence to survive. The Tribunal therefore deleted all the penalties for the years in appeal and rejected the request to keep the matters pending, while leaving the Department free to seek revival if it later succeeded in the quantum proceedings.
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