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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Warrant of arrest - willful defaulter - Recovery of arrears of sales tax dues - The reports of the revenue officials that, the defaulter is living in a highly financial family background with financially sound relatives and friends are not factors relevant under S. 65 of the Act to make an order for the detention of the defaulter in the civil prison. No objective assessment of facts and the factors relevant under S. 65 of the Act was made by the District Collector to make an order for the detention of the defaulter in civil prison. There is nothing on record before the District Collector to hold that the defaulter has means to pay the arrears, or the defaulter is willfully withholding payment of arrears of sales tax or has dishonestly transferred his property or guilty of fraudulent conduct. - the defaulter is set free - HC
Warrant of arrest - willful defaulter - Recovery of arrears of sales tax dues - The reports of the revenue officials that, the defaulter is living in a highly financial family background with financially sound relatives and friends are not factors relevant under S. 65 of the Act to make an order for the detention of the defaulter in the civil prison. No objective assessment of facts and the factors relevant under S. 65 of the Act was made by the District Collector to make an order for the detention of the defaulter in civil prison. There is nothing on record before the District Collector to hold that the defaulter has means to pay the arrears, or the defaulter is willfully withholding payment of arrears of sales tax or has dishonestly transferred his property or guilty of fraudulent conduct. - the defaulter is set free - HC
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