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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Interest on delayed refund - Extended Period of limitation - Section 6 of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 and section 11BB of the Central Excise Act, 1944 - The order of refund was passed within the extended time limit and, therefore, is saved by Section 6 of the 2020 Act from being subjected to the rigors of Section 11BB of Central Excise Act - It is well settled that Tax Laws are to be interpreted strictly in terms of the terminology employed by legislature. - HC
Interest on delayed refund - Extended Period of limitation - Section 6 of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 and section 11BB of the Central Excise Act, 1944 - The order of refund was passed within the extended time limit and, therefore, is saved by Section 6 of the 2020 Act from being subjected to the rigors of Section 11BB of Central Excise Act - It is well settled that Tax Laws are to be interpreted strictly in terms of the terminology employed by legislature. - HC
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