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...
Availability of a statutory appellate remedy against GST registration cancellation and rejection of revocation ordinarily precludes adjudication of factual disputes in writ jurisdiction. Appeals lay against both orders; therefore, factual contentions remained open for determination by the appellate authority. Where the revocation-rejection order was undated but served on 22 August 2026, the service date was directed to be treated as the order date for pursuing the appellate remedy. The taxpayer was permitted to file appeals against both orders within two weeks, for expeditious disposal.
Availability of a statutory appellate remedy against GST registration cancellation and rejection of revocation ordinarily precludes adjudication of factual disputes in writ jurisdiction. Appeals lay against both orders; therefore, factual contentions remained open for determination by the appellate authority. Where the revocation-rejection order was undated but served on 22 August 2026, the service date was directed to be treated as the order date for pursuing the appellate remedy. The taxpayer was permitted to file appeals against both orders within two weeks, for expeditious disposal.
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