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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Notice/summons issued by the Central Tax Authority whereas adjudication u/s 74 had been made by the State Authority - the initiation of the proceeding for imposition of tax and penalty was with the issuance of the notice under Section 74 as contained in Chapter XV of UPGST Act and the inquiry under Section 70 of the Act was independent - - It goes without saying that all issues being raised by the petitioner herein including the issue of non-service of notice before passing the order u/s 74 shall have to be adjudicated by the appellate authority without being influenced by any of the observations made. - HC
Notice/summons issued by the Central Tax Authority whereas adjudication u/s 74 had been made by the State Authority - the initiation of the proceeding for imposition of tax and penalty was with the issuance of the notice under Section 74 as contained in Chapter XV of UPGST Act and the inquiry under Section 70 of the Act was independent - - It goes without saying that all issues being raised by the petitioner herein including the issue of non-service of notice before passing the order u/s 74 shall have to be adjudicated by the appellate authority without being influenced by any of the observations made. - HC
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