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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Refund of GST - rejection on the ground of time limitation - petitioner submits that in view of the deficiency pointed out in the earlier proceedings, the petitioner was unable to upload the refund applications for the period commencing from February 2019 to December 2019 and that the limitation for filing refund claim had expired under Section 54 of the CGST Act, 2017 - in view of earlier decision of HC, writ petition is disposed off by directing the respondent to consider the petitioner's representation dated 10.12.2021 without expressing any opinion on merits. - HC
Refund of GST - rejection on the ground of time limitation - petitioner submits that in view of the deficiency pointed out in the earlier proceedings, the petitioner was unable to upload the refund applications for the period commencing from February 2019 to December 2019 and that the limitation for filing refund claim had expired under Section 54 of the CGST Act, 2017 - in view of earlier decision of HC, writ petition is disposed off by directing the respondent to consider the petitioner's representation dated 10.12.2021 without expressing any opinion on merits. - HC
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