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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Seeking protection form arrest - The matter involves availment of huge amount of tax input credit. Therefore, a thorough investigation is certainly required. Any protection granted to the applicant from arrest would rather, be a sure impediment in such investigation. Such being the position, the submission of the applicant that personal liberty of an individual needs to be given paramount importance need not be given undue significance. Rather, the interest of the nation and society cannot be overlooked in such cases. - DSC
Seeking protection form arrest - The matter involves availment of huge amount of tax input credit. Therefore, a thorough investigation is certainly required. Any protection granted to the applicant from arrest would rather, be a sure impediment in such investigation. Such being the position, the submission of the applicant that personal liberty of an individual needs to be given paramount importance need not be given undue significance. Rather, the interest of the nation and society cannot be overlooked in such cases. - DSC
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