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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Disallowance of exemption on second interstate Sales - requirement under the statutory prescription is that an assessee should file E1 and C declaration forms. This has been done admittedly by the revision petitioner. Therefore, an obligation, which is not cast upon the assessee under the statutory prescription contained in Section 6(2) of the CST Act, 1956 cannot be imposed upon the revision petitioner by the Tribunal - HC
Disallowance of exemption on second interstate Sales - requirement under the statutory prescription is that an assessee should file E1 and C declaration forms. This has been done admittedly by the revision petitioner. Therefore, an obligation, which is not cast upon the assessee under the statutory prescription contained in Section 6(2) of the CST Act, 1956 cannot be imposed upon the revision petitioner by the Tribunal - HC
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