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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Constitutional validity of the amendments to the provisions of the Foreign Contribution (Regulation) Act, 2010 - Infringement of fundamental rights - - Having noted that the provision became necessary for efficient regulation of foreign contribution on real-time basis, it can neither be said to be manifestly arbitrary nor irrational much less without legitimate objective of the State. Accordingly, there are no hesitation in negating the challenge to these provisions as being violative of Articles 14, 19 and 21 of the Constitution - SC
Constitutional validity of the amendments to the provisions of the Foreign Contribution (Regulation) Act, 2010 - Infringement of fundamental rights - - Having noted that the provision became necessary for efficient regulation of foreign contribution on real-time basis, it can neither be said to be manifestly arbitrary nor irrational much less without legitimate objective of the State. Accordingly, there are no hesitation in negating the challenge to these provisions as being violative of Articles 14, 19 and 21 of the Constitution - SC
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