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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Doctrine of Promissory Estoppel - Withdrawal of subsidy granted on account of change of opinion - definition of captive power plant - benefit of exemption of capital investment made in the captive power plant - the withdrawal of the benefit granted to the petitioner by the State level committee through its decision and the order of the State Appellate Forum is illegal and unjustified and is liable to be and is accordingly set aside/quashed with consequences to flow. - HC
Doctrine of Promissory Estoppel - Withdrawal of subsidy granted on account of change of opinion - definition of captive power plant - benefit of exemption of capital investment made in the captive power plant - the withdrawal of the benefit granted to the petitioner by the State level committee through its decision and the order of the State Appellate Forum is illegal and unjustified and is liable to be and is accordingly set aside/quashed with consequences to flow. - HC
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