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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Seeking return of original documents seized from the petitioner at the time of search - This Court is of the opinion that for issuing a direction to the respondent, it is mandatory for the petitioner to approach the respondent with appropriate application. When the respondent filed a counter affidavit stating that the petitioner has not even approached the respondent for such release as such sought for in the present writ petition, then this Court cannot consider the relief. - HC
Seeking return of original documents seized from the petitioner at the time of search - This Court is of the opinion that for issuing a direction to the respondent, it is mandatory for the petitioner to approach the respondent with appropriate application. When the respondent filed a counter affidavit stating that the petitioner has not even approached the respondent for such release as such sought for in the present writ petition, then this Court cannot consider the relief. - HC
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