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 summon issued - for want of furnishing of certain documents, that has been quashed by this Court and accordingly, the respondent was directed to proceed further for furnishing the document - Only in pursuance of the said direction issued by this Court permitting the documents sought for by the petitioner and also permitting the petitioner to cross examine the witnesses as he sought for, now the respondent has fixed the hearing and by thus, the present summon dated 19.08.2021 has been issued. - This Court feels that the challenge now made by the petitioner against the impugned summons cannot be a successful challenge - HC
Validity of summon issued - for want of furnishing of certain documents, that has been quashed by this Court and accordingly, the respondent was directed to proceed further for furnishing the document - Only in pursuance of the said direction issued by this Court permitting the documents sought for by the petitioner and also permitting the petitioner to cross examine the witnesses as he sought for, now the respondent has fixed the hearing and by thus, the present summon dated 19.08.2021 has been issued. - This Court feels that the challenge now made by the petitioner against the impugned summons cannot be a successful challenge - HC
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