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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Cancellation of registration of petitioner - petitioner firm remained ignorant of the order of the cancellation - The knowledge, which the petitioner attributes, that he could not obtain the knowledge, for a period of 477 days, in fact smacks a sense of irresponsibility for an assessee, who is facing an order of cancellation of its registration rendered on 21.09.2019, and particularly when the assessee i.e. the petitioner was, attributing its responsibility on the Advocate, without there being any pleading to the said effect - Since the appeal itself has been dismissed on the ground of limitation, the writ remedy would not be available to the petitioner. - HC
Cancellation of registration of petitioner - petitioner firm remained ignorant of the order of the cancellation - The knowledge, which the petitioner attributes, that he could not obtain the knowledge, for a period of 477 days, in fact smacks a sense of irresponsibility for an assessee, who is facing an order of cancellation of its registration rendered on 21.09.2019, and particularly when the assessee i.e. the petitioner was, attributing its responsibility on the Advocate, without there being any pleading to the said effect - Since the appeal itself has been dismissed on the ground of limitation, the writ remedy would not be available to the petitioner. - HC
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