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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Jurisdiction to issue SCN - validity of appointment of officers of DGCEI as ‘Central Excise Officers’ having all India jurisdiction - Though the summons emanate from the office of the Deputy Director of Directorate General of Central Intelligence, the file is transferred to the competent authority. The show cause notice is issued by the proper officer. - The show cause notice is within the jurisdiction and not without, as contended. Therefore, the petitioner has to answer to the show cause notice and further proceedings to take place in accordance with law. - HC
Jurisdiction to issue SCN - validity of appointment of officers of DGCEI as ‘Central Excise Officers’ having all India jurisdiction - Though the summons emanate from the office of the Deputy Director of Directorate General of Central Intelligence, the file is transferred to the competent authority. The show cause notice is issued by the proper officer. - The show cause notice is within the jurisdiction and not without, as contended. Therefore, the petitioner has to answer to the show cause notice and further proceedings to take place in accordance with law. - HC
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