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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Denial of Input Tax Credit - spare parts of loader and tipper - denial of credit on the ground that loader and tipper are 'vehicles' - the exclusion clause will not be applicable in the case in hand - the tipper and loader are captively used for manufacturing activity within the mining area where the stone crushing plant is situated, are covered under the definition of “capital goods”, is entitled for Input Tax Credit under section 13(1)(b) of the U.P. VAT Act. - HC
Denial of Input Tax Credit - spare parts of loader and tipper - denial of credit on the ground that loader and tipper are 'vehicles' - the exclusion clause will not be applicable in the case in hand - the tipper and loader are captively used for manufacturing activity within the mining area where the stone crushing plant is situated, are covered under the definition of “capital goods”, is entitled for Input Tax Credit under section 13(1)(b) of the U.P. VAT Act. - HC
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