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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Validity of Show Cause notice and order in original - Maintainability of petition - Benefit of exemption - Essentiality Certificate - import of drill ship - The order-in-original dated 27th February, 2017 suffers from illegality as well as irrationality which constitute vices in the decision making process, attracting judicial review. Evaluation of facts by the Principal Commissioner, upon such review, leads to the conclusion that the facts taken as a whole did not logically warrant the conclusion he did reach, for which the said order is liable to be invalidated. - HC
Validity of Show Cause notice and order in original - Maintainability of petition - Benefit of exemption - Essentiality Certificate - import of drill ship - The order-in-original dated 27th February, 2017 suffers from illegality as well as irrationality which constitute vices in the decision making process, attracting judicial review. Evaluation of facts by the Principal Commissioner, upon such review, leads to the conclusion that the facts taken as a whole did not logically warrant the conclusion he did reach, for which the said order is liable to be invalidated. - HC
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