Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
COVID-19-related fixed overheads incurred during lockdown to retain employees and maintain business continuity were treated as extraordinary, non-operating costs and excluded from the tested party's operating cost for TNMM profitability analysis. Capacity underutilisation may warrant an adjustment; where comparable companies' data is not publicly available, transfer-pricing authorities should obtain it before determining the adjustment. Transfer-pricing adjustments under Chapter X are confined to international transactions with associated enterprises and cannot extend to unrelated-party transactions. Bad-debt double-addition claims require verification where the amount was allegedly already offered to tax. Working-capital adjustments require evidence that differences materially affected price, cost or profits; absent that evidence, reconsideration depends on furnishing supporting particulars.
COVID-19-related fixed overheads incurred during lockdown to retain employees and maintain business continuity were treated as extraordinary, non-operating costs and excluded from the tested party's operating cost for TNMM profitability analysis. Capacity underutilisation may warrant an adjustment; where comparable companies' data is not publicly available, transfer-pricing authorities should obtain it before determining the adjustment. Transfer-pricing adjustments under Chapter X are confined to international transactions with associated enterprises and cannot extend to unrelated-party transactions. Bad-debt double-addition claims require verification where the amount was allegedly already offered to tax. Working-capital adjustments require evidence that differences materially affected price, cost or profits; absent that evidence, reconsideration depends on furnishing supporting particulars.
Note: It is a system-generated summary and is for quick reference only.
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