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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Priority of charge on the land of the 7th respondent - Recovery of Sales Tax dues - As the 7th respondent ceased to be a Power of Attorney holder of the 6th respondent prior to the coming into force of Section 19C, this Court is of the considered view that protective assessment proceedings under Section 19C could not have been legally invoked against the 7th respondent. - The revenue recovery proceedings initiated by respondents 1 to 4 against the 7 th respondent for recovery of tax dues of the 6th respondent is illegal. All proceedings against the 7th respondent including the attachment of his property for recovery of such dues, are therefore illegal. - HC
Priority of charge on the land of the 7th respondent - Recovery of Sales Tax dues - As the 7th respondent ceased to be a Power of Attorney holder of the 6th respondent prior to the coming into force of Section 19C, this Court is of the considered view that protective assessment proceedings under Section 19C could not have been legally invoked against the 7th respondent. - The revenue recovery proceedings initiated by respondents 1 to 4 against the 7 th respondent for recovery of tax dues of the 6th respondent is illegal. All proceedings against the 7th respondent including the attachment of his property for recovery of such dues, are therefore illegal. - HC
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