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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Levy of KST Act and KVAT Act on Liquor - right for disallowing the ITC claimed by the petitioner - There is no cavil with respect to the legal principle enunciated by the Hon’ble Apex Court regarding the speech made by the Hon’ble Finance Minister in moving the Bill would be significant in interpreting the provision. But the input tax credit has to be determined as per section 10 of the KVAT Act. There was no bar for the assessee to collect the output tax in its entirety by its buyers. - HC
Levy of KST Act and KVAT Act on Liquor - right for disallowing the ITC claimed by the petitioner - There is no cavil with respect to the legal principle enunciated by the Hon’ble Apex Court regarding the speech made by the Hon’ble Finance Minister in moving the Bill would be significant in interpreting the provision. But the input tax credit has to be determined as per section 10 of the KVAT Act. There was no bar for the assessee to collect the output tax in its entirety by its buyers. - HC
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