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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Provisional attachment of bank accounts of the opponents - In fact so far as the controversy raised in the main matters is concerned, the same has come to an end today. - The matter as on date has reached to the stage of issue of SCN to the opponents. - It will be open for the department to issue a show cause notice in the manner they propose to and if the opponents are aggrieved in any manner with the contents of the show cause notice, they can raise the issues accordingly by way of their reply. As on date, there is nothing we need to clarify. - HC
Provisional attachment of bank accounts of the opponents - In fact so far as the controversy raised in the main matters is concerned, the same has come to an end today. - The matter as on date has reached to the stage of issue of SCN to the opponents. - It will be open for the department to issue a show cause notice in the manner they propose to and if the opponents are aggrieved in any manner with the contents of the show cause notice, they can raise the issues accordingly by way of their reply. As on date, there is nothing we need to clarify. - HC
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