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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Demand of interest on recovery of excess duty drawback claim - Section 75A(2) - when the petitioner realized that there was an excess claim and grant of drawback, he had deposited the same prior to issuance of SCN - Since the petitioner had repaid the drawback even prior to the demand, the respondents will not be empowered to claim any interest.
Demand of interest on recovery of excess duty drawback claim - Section 75A(2) - when the petitioner realized that there was an excess claim and grant of drawback, he had deposited the same prior to issuance of SCN - Since the petitioner had repaid the drawback even prior to the demand, the respondents will not be empowered to claim any interest.
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