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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Revision of GSTR 3B - the adjudication order is clearly appealable - The writ petition in extraordinary jurisdiction under article 226 of the Constitution of India is not entertained - Once the appeal filed by the assessee is allowed and it is contested that GSTR 3B for the month of March, 2019 suffered from inadvertent mistakes upon evidence led to establish that fact, the appellate authority would have to record a finding in that regard and adjudicate the issue accordingly. If any tax amount is found deposited in excess, over and above, the liability admitted or adjudged for the month of April, 2019, the petitioner may remain entitled to claim benefit of the same in appropriate proceeding, in accordance with law. - HC
Revision of GSTR 3B - the adjudication order is clearly appealable - The writ petition in extraordinary jurisdiction under article 226 of the Constitution of India is not entertained - Once the appeal filed by the assessee is allowed and it is contested that GSTR 3B for the month of March, 2019 suffered from inadvertent mistakes upon evidence led to establish that fact, the appellate authority would have to record a finding in that regard and adjudicate the issue accordingly. If any tax amount is found deposited in excess, over and above, the liability admitted or adjudged for the month of April, 2019, the petitioner may remain entitled to claim benefit of the same in appropriate proceeding, in accordance with law. - HC
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