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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MEIS - Seeking direction to remove the name of the petitioner from the Denied Entity List - benefit of Merchandise Export from India Scheme - The contention that unless and until the petitioner pays up the entire duty and penalty imposed under the orders passed by the DGFT and custom authorities the petitioner cannot claim any export incentive under the new scheme is completely unacceptable. Both the orders are under challenge before the first appellate authorities. Respective statutes require pre-deposit of certain amounts upon which rest of the recoveries would be suspended. - HC
MEIS - Seeking direction to remove the name of the petitioner from the Denied Entity List - benefit of Merchandise Export from India Scheme - The contention that unless and until the petitioner pays up the entire duty and penalty imposed under the orders passed by the DGFT and custom authorities the petitioner cannot claim any export incentive under the new scheme is completely unacceptable. Both the orders are under challenge before the first appellate authorities. Respective statutes require pre-deposit of certain amounts upon which rest of the recoveries would be suspended. - HC
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