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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Rejection of concessional rate of tax applicable to sales made in favour of Lakshadweep Administration - In the process of interpretation or application, relevant expression chosen by the legislature or the executive ought not to be ignored or diluted. The case of dealer if accepted, the same would result in overlooking the clear expression of the rule making authority. The claim of dealer for concessional rate without placing on record all the requirements of Rule 12C is misconceived and liable to be rejected - The misuse of concessional rate of tax cannot be overlooked while accepting a purposive interpretation - HC
Rejection of concessional rate of tax applicable to sales made in favour of Lakshadweep Administration - In the process of interpretation or application, relevant expression chosen by the legislature or the executive ought not to be ignored or diluted. The case of dealer if accepted, the same would result in overlooking the clear expression of the rule making authority. The claim of dealer for concessional rate without placing on record all the requirements of Rule 12C is misconceived and liable to be rejected - The misuse of concessional rate of tax cannot be overlooked while accepting a purposive interpretation - HC
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