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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Levy of CST - inter-state sales effected without C-Form declarations - amount claimed as deduction by the petitioner to be in the nature of discount requiring compliance of Rule 3(2)(c) of the Karnataka Value Added Tax Rules, 2005 or not - Though the petitioner has contended before the Tribunal that issuing of credit note to the purchasing dealers could not be construed as discount, even assuming that it is discount not reflected in the books of accounts, the principles enunciated by the Hon’ble Apex Court in Southern Motors, would certainly apply to the facts of the case on hand. - Benefit allowed - HC
Levy of CST - inter-state sales effected without C-Form declarations - amount claimed as deduction by the petitioner to be in the nature of discount requiring compliance of Rule 3(2)(c) of the Karnataka Value Added Tax Rules, 2005 or not - Though the petitioner has contended before the Tribunal that issuing of credit note to the purchasing dealers could not be construed as discount, even assuming that it is discount not reflected in the books of accounts, the principles enunciated by the Hon’ble Apex Court in Southern Motors, would certainly apply to the facts of the case on hand. - Benefit allowed - HC
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