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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Exercise of Revisional Jurisdiction after seven years - the bar of limitation, to initiate revisional jurisdiction under Section 46 (1) of the VAT Act, 2005 within five years of the notice of order sought to be revised, clearly applied to the facts of the instant case. The Revisional Authority could not revise the order dated 10.10.2002 passed by the Appellate Authority by exercising revisional jurisdiction initiated after lapse of five years. - HC
Exercise of Revisional Jurisdiction after seven years - the bar of limitation, to initiate revisional jurisdiction under Section 46 (1) of the VAT Act, 2005 within five years of the notice of order sought to be revised, clearly applied to the facts of the instant case. The Revisional Authority could not revise the order dated 10.10.2002 passed by the Appellate Authority by exercising revisional jurisdiction initiated after lapse of five years. - HC
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