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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Benefit of advance authorisations - There are several matters in dispute between parties, viz. petitioner and respondents. Petitioner claims that imported goods undergo certain process, which is a manufacturing process, whereas test reports and factual position contended by the other side has been stated to be otherwise. In such disputed scenario, it is not be a case where it can be said that the revenue department is acting without powers or authority having regard to provisions referred to - HC
Benefit of advance authorisations - There are several matters in dispute between parties, viz. petitioner and respondents. Petitioner claims that imported goods undergo certain process, which is a manufacturing process, whereas test reports and factual position contended by the other side has been stated to be otherwise. In such disputed scenario, it is not be a case where it can be said that the revenue department is acting without powers or authority having regard to provisions referred to - HC
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