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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Seizure and confiscation of goods - Carrying Gold without delivery challan - Validity of proceedings initiated u/s 130 - The question whether absence of mandatory documents in the particular case constitute an intention to evade tax or not is a matter within the realm of satisfaction of the Proper Officer. Interference in the satisfaction exercised by the Proper Officer, when the conclusion is supported by the circumstances surrounding the transaction, warrants no interference by this Court, as otherwise, the scheme and purport of the Act will be affected. - HC
Seizure and confiscation of goods - Carrying Gold without delivery challan - Validity of proceedings initiated u/s 130 - The question whether absence of mandatory documents in the particular case constitute an intention to evade tax or not is a matter within the realm of satisfaction of the Proper Officer. Interference in the satisfaction exercised by the Proper Officer, when the conclusion is supported by the circumstances surrounding the transaction, warrants no interference by this Court, as otherwise, the scheme and purport of the Act will be affected. - HC
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