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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Jurisdiction - appropriate authority to complete the proceedings - state authority or central authority - although the action was undertaken under Section 67 of the Act by the DGGI, AZU, yet the two summons came to be issued: one by the Deputy Commissioner of State Tax and another by the DGGI, Surat - This writ application is disposed off with a direction to the DGGI, AZU, Ahmedabad to look into the matter and ensure that no undue harassment is caused to the writ applicant by different authorities on the same subject matter. - HC
Jurisdiction - appropriate authority to complete the proceedings - state authority or central authority - although the action was undertaken under Section 67 of the Act by the DGGI, AZU, yet the two summons came to be issued: one by the Deputy Commissioner of State Tax and another by the DGGI, Surat - This writ application is disposed off with a direction to the DGGI, AZU, Ahmedabad to look into the matter and ensure that no undue harassment is caused to the writ applicant by different authorities on the same subject matter. - HC
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