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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Misreporting eligible IGST input tax credit under CGST and SGST heads is a technical classification error where aggregate eligible credit has not been exceeded and underlying eligibility is undisputed. Electronic credit ledger balances across IGST, CGST and SGST must be assessed collectively before sustaining an excess-credit demand. Limited verification of unclaimed eligible IGST credit is required; if available, the demand, interest and penalty must be dropped, with consequential ITC restoration or adjustment according to law.
Misreporting eligible IGST input tax credit under CGST and SGST heads is a technical classification error where aggregate eligible credit has not been exceeded and underlying eligibility is undisputed. Electronic credit ledger balances across IGST, CGST and SGST must be assessed collectively before sustaining an excess-credit demand. Limited verification of unclaimed eligible IGST credit is required; if available, the demand, interest and penalty must be dropped, with consequential ITC restoration or adjustment according to law.
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