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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GST Fraud - Misuse of Aadhar and PAN cards of writ petitioner - offence of issuing invoice without supply of goods in violation of TN-GST, C-GST Acts and rules thereunder - levy of penalty u/s 122(1)(ii) of TNGST and CGST Acts - a criminal complaint has been lodged by the writ petitioner and investigation is under-way - it would only be appropriate to set aside the impugned order without expressing any view or opinion on the merits of the matter, leaving it open to respondents to proceed afresh either against writ petitioner or any other entity or person depending on the outcome of investigation that is under-way qua alleged misuse of writ petitioner's Aadhar and PAN cards to obtain a fake registration. - HC
GST Fraud - Misuse of Aadhar and PAN cards of writ petitioner - offence of issuing invoice without supply of goods in violation of TN-GST, C-GST Acts and rules thereunder - levy of penalty u/s 122(1)(ii) of TNGST and CGST Acts - a criminal complaint has been lodged by the writ petitioner and investigation is under-way - it would only be appropriate to set aside the impugned order without expressing any view or opinion on the merits of the matter, leaving it open to respondents to proceed afresh either against writ petitioner or any other entity or person depending on the outcome of investigation that is under-way qua alleged misuse of writ petitioner's Aadhar and PAN cards to obtain a fake registration. - HC
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