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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Refusal to supply documents seized - A mere statement that it will prejudicially affect the investigation would be only chanting the language of the section, there must be cogent reasons to withhold giving of copies and the said person need not give justification why he needs the copies of the documents seized - If the right to get copies of the documents and the power of the authorities to refuse the same has to be balanced - refusal unjustified
Refusal to supply documents seized - A mere statement that it will prejudicially affect the investigation would be only chanting the language of the section, there must be cogent reasons to withhold giving of copies and the said person need not give justification why he needs the copies of the documents seized - If the right to get copies of the documents and the power of the authorities to refuse the same has to be balanced - refusal unjustified
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