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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Refund of Mica Cess - levy of said mica cess got repealed vide the Finance Act, 2016 - effective date of repealment - cess applicable under the repealed Act was very much effective till the date of receipt of the Hon’ble President’s assent. The same being the legal position, no contrary conclusion can be drawn on the basis of contents of Office Memorandum dated 27.07.2016 as relied by the appellant. - AT
Refund of Mica Cess - levy of said mica cess got repealed vide the Finance Act, 2016 - effective date of repealment - cess applicable under the repealed Act was very much effective till the date of receipt of the Hon’ble President’s assent. The same being the legal position, no contrary conclusion can be drawn on the basis of contents of Office Memorandum dated 27.07.2016 as relied by the appellant. - AT
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