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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Principle of promissory estoppel - Levy of penalty - Amendment in the exemption scheme - Tribunal was wholly justified in invoking the doctrine of principle of promissory estoppel and holding that the appellant was bound by the assurances given to the respondent and cannot change the conditions to the detriment of the respondent. - HC
Principle of promissory estoppel - Levy of penalty - Amendment in the exemption scheme - Tribunal was wholly justified in invoking the doctrine of principle of promissory estoppel and holding that the appellant was bound by the assurances given to the respondent and cannot change the conditions to the detriment of the respondent. - HC
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