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 statement issued in prescribed form SVLDRS 3 - tax liability that was due and payable - setting off of amounts already paid towards tax - if a declarant has made a pre-deposit or other deposits which exceed the amount payable, as indicated in the statement issued by the designated committee, the said amount shall not be refunded as per provisions of sub-section (2) of section 130 of 2019 Act. - the pre-deposit made by the petitioner is less than the amount stated in the impugned statement and therefore, in this matter, the petitioner steers clear of the aforesaid provision - the construction of provisions of section 123 (d) cannot enure to the benefit of the revenue. - HC
Validity of statement issued in prescribed form SVLDRS 3 - tax liability that was due and payable - setting off of amounts already paid towards tax - if a declarant has made a pre-deposit or other deposits which exceed the amount payable, as indicated in the statement issued by the designated committee, the said amount shall not be refunded as per provisions of sub-section (2) of section 130 of 2019 Act. - the pre-deposit made by the petitioner is less than the amount stated in the impugned statement and therefore, in this matter, the petitioner steers clear of the aforesaid provision - the construction of provisions of section 123 (d) cannot enure to the benefit of the revenue. - HC
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