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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Refund the monies lying in the Capital Gains Account Scheme (CGAS) with the bank along with interest at prevailing rates - The operation of the account in question is a matter of contract qua the petitioners and R2 and the petitioners are at liberty to give such instructions to R2 as they may wish to, in this regard. Form-G which is to be approved by the assessing authority will have no application in this case since the transaction giving rise to capital gains has not been captured by the Department. In any event, today, R1 does not have any claim towards the amounts in the bank accounts. - HC
Refund the monies lying in the Capital Gains Account Scheme (CGAS) with the bank along with interest at prevailing rates - The operation of the account in question is a matter of contract qua the petitioners and R2 and the petitioners are at liberty to give such instructions to R2 as they may wish to, in this regard. Form-G which is to be approved by the assessing authority will have no application in this case since the transaction giving rise to capital gains has not been captured by the Department. In any event, today, R1 does not have any claim towards the amounts in the bank accounts. - HC
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