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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Rejection of extension of time for payment of the last installment of Tax under Income Disclosure Scheme, 2016 (IDS) - The case on hand is not one of illegal recovery of tax by the Revenue, or in other words, any tax paid by the assessee under mistake of law. This is a case of default on the part of the writ applicant as an assessee, and the consequences of the default are itself provided under the scheme in the form of Clause 191. - HC
Rejection of extension of time for payment of the last installment of Tax under Income Disclosure Scheme, 2016 (IDS) - The case on hand is not one of illegal recovery of tax by the Revenue, or in other words, any tax paid by the assessee under mistake of law. This is a case of default on the part of the writ applicant as an assessee, and the consequences of the default are itself provided under the scheme in the form of Clause 191. - HC
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