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 143(1)(a) intimation lost its independent existence after the Assessing Officer reconsidered the same adjustments in scrutiny assessment under section 143(3) and granted relief on the rectification request. Applying the merger principle, the Tribunal held that the appeal against the intimation had become infructuous, and once that appeal was infructuous, the Revenue's further appeal against the first appellate order in the same matter was also infructuous. The Revenue's appeal was therefore dismissed on that basis.
Section 143(1)(a) intimation lost its independent existence after the Assessing Officer reconsidered the same adjustments in scrutiny assessment under section 143(3) and granted relief on the rectification request. Applying the merger principle, the Tribunal held that the appeal against the intimation had become infructuous, and once that appeal was infructuous, the Revenue's further appeal against the first appellate order in the same matter was also infructuous. The Revenue's appeal was therefore dismissed on that basis.
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