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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Input Tax Credit - failure to register as VAT dealer - Assessee applied for VAT registration only on 18.05.2007 i.e., long after the expiry of stipulated period. Therefore, the 2nd respondent rightly rejected his claim and passed the impugned order directing the petitioner to pay VAT @ 12.5% and also treating him as VAT dealer instead of imposing @ 1% tax treating as turnover tax dealer. - HC
Input Tax Credit - failure to register as VAT dealer - Assessee applied for VAT registration only on 18.05.2007 i.e., long after the expiry of stipulated period. Therefore, the 2nd respondent rightly rejected his claim and passed the impugned order directing the petitioner to pay VAT @ 12.5% and also treating him as VAT dealer instead of imposing @ 1% tax treating as turnover tax dealer. - HC
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