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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Recovery of arrears of sales tax and penalty from the Legal Heirs of deceased - - The impugned order contains a fatal flaw insofar as it is addressed to the petitioner Firm and one of its partner, both not being legal heirs of the deceased sole proprietor. The Firm and Partner cannot thus be fastened with the liability of the deceased proprietor.
Recovery of arrears of sales tax and penalty from the Legal Heirs of deceased - - The impugned order contains a fatal flaw insofar as it is addressed to the petitioner Firm and one of its partner, both not being legal heirs of the deceased sole proprietor. The Firm and Partner cannot thus be fastened with the liability of the deceased proprietor.
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