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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Accrual of GST liability - when is the ‘date of receipt of payment’ where no tax invoice is issued under Section 31 - agreement for the sale of flats in a project - Section 13(2) uses ‘earliest’ not once, but twice. - Saifee Developers had absolutely no justification in not paying the remaining GST and interest. It is unclear whether it has even paid the stamp duty on the MoU/Agreement as yet. It cannot be in default and yet continue to squat on a protective ad-interim order granted in exercise of equitable and discretionary jurisdiction - HC
Accrual of GST liability - when is the ‘date of receipt of payment’ where no tax invoice is issued under Section 31 - agreement for the sale of flats in a project - Section 13(2) uses ‘earliest’ not once, but twice. - Saifee Developers had absolutely no justification in not paying the remaining GST and interest. It is unclear whether it has even paid the stamp duty on the MoU/Agreement as yet. It cannot be in default and yet continue to squat on a protective ad-interim order granted in exercise of equitable and discretionary jurisdiction - HC
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