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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Scope of SCN - The SCN has raised objection only with regard to aspect of unjust enrichment, Whereas, the Adjudicating Authority as well as the Ld. Commissioner (Appeals) had gone into the aspect of nature of services, whether the services fall under works contract service or otherwise - Such an important issue cannot be dealt without making any allegations in the SCN - not permissible
Scope of SCN - The SCN has raised objection only with regard to aspect of unjust enrichment, Whereas, the Adjudicating Authority as well as the Ld. Commissioner (Appeals) had gone into the aspect of nature of services, whether the services fall under works contract service or otherwise - Such an important issue cannot be dealt without making any allegations in the SCN - not permissible
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