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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Powers of officers conducting search and seizure to remain stayed in the premises for unlimited period - Key person was not found at home during search - Protection of such action u/s 157 of the GST Acts may unleash a regime of terror insofar as the taxable persons are concerned - this court does not condone any alleged illegal acts on the part of the petitioner and in case he has indulged in any illegalities, the law should take its own course. However, the court found it necessary to pass the present order to curb any further abuse of powers in this manner by the authorities under the GST Acts.
Powers of officers conducting search and seizure to remain stayed in the premises for unlimited period - Key person was not found at home during search - Protection of such action u/s 157 of the GST Acts may unleash a regime of terror insofar as the taxable persons are concerned - this court does not condone any alleged illegal acts on the part of the petitioner and in case he has indulged in any illegalities, the law should take its own course. However, the court found it necessary to pass the present order to curb any further abuse of powers in this manner by the authorities under the GST Acts.
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