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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
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Parallel GST proceedings on identical issues for the same assessment period cannot be sustained where Central GST authorities have already issued an order and the related appeal is pending before the appellate authority. The State GST assessment and rectification orders addressed the same issues already adjudicated under Central GST. Consequently, the subsequent State GST proceedings were quashed, and the writ petition succeeded.
Parallel GST proceedings on identical issues for the same assessment period cannot be sustained where Central GST authorities have already issued an order and the related appeal is pending before the appellate authority. The State GST assessment and rectification orders addressed the same issues already adjudicated under Central GST. Consequently, the subsequent State GST proceedings were quashed, and the writ petition succeeded.
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