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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Validity of adjudication of SCN after a long gap, i.e. 12 years - SCN has been issued on 14.05.2009 and is pending till date with finalization of proceedings as contemplate under Section 28 of the Customs Act, 1962 - The counter filed by the revenue does not reveal any circumstances, which would justify the elapse of time from 2009 till date, of more than twelve years to keep the proceedings pending. The normal defence offered is that the issue has been transferred to the call book. Even this defence has not raised in this case. The explanation offered, to the effect that there was a change in incumbent officer is hardly acceptable. - HC
Validity of adjudication of SCN after a long gap, i.e. 12 years - SCN has been issued on 14.05.2009 and is pending till date with finalization of proceedings as contemplate under Section 28 of the Customs Act, 1962 - The counter filed by the revenue does not reveal any circumstances, which would justify the elapse of time from 2009 till date, of more than twelve years to keep the proceedings pending. The normal defence offered is that the issue has been transferred to the call book. Even this defence has not raised in this case. The explanation offered, to the effect that there was a change in incumbent officer is hardly acceptable. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4826 
Join Channel 
