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 SCN - Reversal of Input Tax Credit - In the show-cause notice, the respondents have alleged that the notice i.e. petitioner has willfully filed the return on a later date than the due date of filing of GSTR 3B for the financial year 2018-19 to accommodate ITC, therefore, it is a matter of adjudication whether there was any willful delay on the part of the petitioner to submit the return or not? - Now the show-cause notice has been issued, therefore, the petitioner is required to file a return to the show-cause notice before the competent authority. - HC
Validity of SCN - Reversal of Input Tax Credit - In the show-cause notice, the respondents have alleged that the notice i.e. petitioner has willfully filed the return on a later date than the due date of filing of GSTR 3B for the financial year 2018-19 to accommodate ITC, therefore, it is a matter of adjudication whether there was any willful delay on the part of the petitioner to submit the return or not? - Now the show-cause notice has been issued, therefore, the petitioner is required to file a return to the show-cause notice before the competent authority. - HC
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