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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Validity of appeal preferred by the respondent (revenue) against an order of assessment under the Finance Act, 1994 - amnesty scheme in vogue - The petitioner cannot also be seen as prejudiced in any manner merely because the intimation of the revenue appeal was received by him after the expiry of the amnesty scheme. His option for the amnesty scheme was not dependent upon whether or not the revenue preferred an appeal against the order of the assessing authority. The petitioner has not made out a case for the reliefs sought for in the writ petition. - HC
Validity of appeal preferred by the respondent (revenue) against an order of assessment under the Finance Act, 1994 - amnesty scheme in vogue - The petitioner cannot also be seen as prejudiced in any manner merely because the intimation of the revenue appeal was received by him after the expiry of the amnesty scheme. His option for the amnesty scheme was not dependent upon whether or not the revenue preferred an appeal against the order of the assessing authority. The petitioner has not made out a case for the reliefs sought for in the writ petition. - HC
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