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...
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GST notices alleging fraud, wilful misrepresentation or suppression must disclose the foundational facts supporting those allegations. Mere reproduction of statutory expressions, without reasons showing application of mind, does not sustain proceedings alleging input tax credit availed through fake invoices without actual supply of goods. Notices lacking sufficient reasons were quashed, while preserving the authority's liberty to issue fresh notices in accordance with law.
GST notices alleging fraud, wilful misrepresentation or suppression must disclose the foundational facts supporting those allegations. Mere reproduction of statutory expressions, without reasons showing application of mind, does not sustain proceedings alleging input tax credit availed through fake invoices without actual supply of goods. Notices lacking sufficient reasons were quashed, while preserving the authority's liberty to issue fresh notices in accordance with law.
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