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 unutilised input tax credit - interest for delayed payment of refund - In view of the categorical assertion made by the learned counsel representing the Revenue that the aforesaid circular and notification would have no application to transactions entered into prior to the aforesaid circular and since admittedly the transactions for refund of unutilised input tax credit claimed pertains to the period July to October, 2017, consequently, there is no lawful impediment in justifying denial of refund of unutilised input tax credit to the petitioner. - HC
Refund of unutilised input tax credit - interest for delayed payment of refund - In view of the categorical assertion made by the learned counsel representing the Revenue that the aforesaid circular and notification would have no application to transactions entered into prior to the aforesaid circular and since admittedly the transactions for refund of unutilised input tax credit claimed pertains to the period July to October, 2017, consequently, there is no lawful impediment in justifying denial of refund of unutilised input tax credit to the petitioner. - HC
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