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 assessment order - recovery of arrears of tax and penalty - The pre-assessment notice was received by the dealer, the order of assessment was communicated to the dealer in the manner known to law. Further, the stand taken by the dealer that they are not carrying on business was found to be false, as could be seen from the inspection report submitted by the Assessing Officer - Writ appeal dismissed - HC
Validity of assessment order - recovery of arrears of tax and penalty - The pre-assessment notice was received by the dealer, the order of assessment was communicated to the dealer in the manner known to law. Further, the stand taken by the dealer that they are not carrying on business was found to be false, as could be seen from the inspection report submitted by the Assessing Officer - Writ appeal dismissed - HC
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