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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Provisional attachment - blocking of Input Tax Credit (ITC) - Now, no longer that grievance continuous in wake of order of the Coordinate Bench dated 04/05/2022. Moreover, as fairly admitted, this is a pre SCN stage in post search period and hence, unlimited period also would not be warranted. - The State has volunteered that this inquiry/investigation should be over in three months’ period but to be on safer side, we would grant four months’ period to the State to complete the present exercise, so that it may not have to once again approach for extension. - HC
Provisional attachment - blocking of Input Tax Credit (ITC) - Now, no longer that grievance continuous in wake of order of the Coordinate Bench dated 04/05/2022. Moreover, as fairly admitted, this is a pre SCN stage in post search period and hence, unlimited period also would not be warranted. - The State has volunteered that this inquiry/investigation should be over in three months’ period but to be on safer side, we would grant four months’ period to the State to complete the present exercise, so that it may not have to once again approach for extension. - HC
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