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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Section 73 of the CGST Act requires GST assessment and demand limitation to be determined separately for each financial year, with reference to the relevant annual return. A composite show cause notice covering multiple financial years improperly combines distinct tax periods, due dates, limitation periods, allegations and response opportunities. High Court precedent is binding within its territorial jurisdiction. The composite notice was quashed, while preserving the respondents' liberty to issue fresh notices separately in accordance with Section 73, subject to any other legal impediment.
Section 73 of the CGST Act requires GST assessment and demand limitation to be determined separately for each financial year, with reference to the relevant annual return. A composite show cause notice covering multiple financial years improperly combines distinct tax periods, due dates, limitation periods, allegations and response opportunities. High Court precedent is binding within its territorial jurisdiction. The composite notice was quashed, while preserving the respondents' liberty to issue fresh notices separately in accordance with Section 73, subject to any other legal impediment.
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TaxTMI 
TaxTMI 
of 4886 
