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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Validity of assessment order -Non-existing dealer - the petitioner being a transporter is deemed to be the owner of the taxable goods and is bound to comply with all the requirements of the Act of 2003. It is not the case of the petitioner that the consignor and the consignee are existent dealers and the consignment itself did not match with the documents. Therefore, there is no reason to doubt the action of the respondents in construing the consignment in question as an attempt to evade the tax. - HC
Validity of assessment order -Non-existing dealer - the petitioner being a transporter is deemed to be the owner of the taxable goods and is bound to comply with all the requirements of the Act of 2003. It is not the case of the petitioner that the consignor and the consignee are existent dealers and the consignment itself did not match with the documents. Therefore, there is no reason to doubt the action of the respondents in construing the consignment in question as an attempt to evade the tax. - HC
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