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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Period of limitation - Validity of assessment order - Extension of time limit in exercise of its power under the proviso to Section 110(2) of the Customs Act, 1962 - The Central Government has now extended the date from 30.09.2020 to 31.12.2020 for completion or compliance of action such as completion of any proceeding or issuance of any order, notice, intimation, notification or sanction or approval, by whatever name called, by any authority, commission, tribunal, by whatever name called. In view of the above notification, the proceedings dated 30.09.2020 though served on 07.10.2020 is within the period extended by the Central Government and thus valid. - HC
Period of limitation - Validity of assessment order - Extension of time limit in exercise of its power under the proviso to Section 110(2) of the Customs Act, 1962 - The Central Government has now extended the date from 30.09.2020 to 31.12.2020 for completion or compliance of action such as completion of any proceeding or issuance of any order, notice, intimation, notification or sanction or approval, by whatever name called, by any authority, commission, tribunal, by whatever name called. In view of the above notification, the proceedings dated 30.09.2020 though served on 07.10.2020 is within the period extended by the Central Government and thus valid. - HC
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