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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GST appellate limitation bound the Appellate Authority, but delay caused by circumstances beyond the taxpayer's control was treated as sufficient cause for condonation to prevent prejudice from denial of a merits hearing. A fresh statutory appeal could therefore be filed within the permitted period for adjudication on merits. Alleged duplicate recovery of GST demand required verification rather than an immediate factual finding; any excess recovery identified on verification was to be refunded with applicable interest.
GST appellate limitation bound the Appellate Authority, but delay caused by circumstances beyond the taxpayer's control was treated as sufficient cause for condonation to prevent prejudice from denial of a merits hearing. A fresh statutory appeal could therefore be filed within the permitted period for adjudication on merits. Alleged duplicate recovery of GST demand required verification rather than an immediate factual finding; any excess recovery identified on verification was to be refunded with applicable interest.
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