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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Closure of proceedings on the ground that appellant has waived their right to a written show cause notice - appellant deposited the demand with interest and penalty under protest to buy peace - in view of the non acceptance of the allegation of the DGCEI by the appellant, as to non receipt of the inputs in question, we hold that the purported waiver is bad and illegal and is not enforceable against the appellant.
Closure of proceedings on the ground that appellant has waived their right to a written show cause notice - appellant deposited the demand with interest and penalty under protest to buy peace - in view of the non acceptance of the allegation of the DGCEI by the appellant, as to non receipt of the inputs in question, we hold that the purported waiver is bad and illegal and is not enforceable against the appellant.
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