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 show cause notice (SCN) - blocking credit ledger Availment of ineligible credit of input tax - fake invoices - When the respondent-Department has duly accepted all the contentions of the petitioner and found the e-way bills and computer generated measurement slip to be correct and genuine documents and the sole reason for initiating the proceedings against this petitioner and passing of the impugned adjudication orders was due to his transaction with M/s Jai Jawan Kastha Bhandar and M/s. Priti Enterprises and when the cases of those assesses have been remanded to the adjudicating authority to pass fresh order in accordance with law; interest of justice demands that the case of this petitioner should also be remitted back to the adjudicating authority, inasmuch as, the sole cause of action does not survives. - HC
Validity of show cause notice (SCN) - blocking credit ledger Availment of ineligible credit of input tax - fake invoices - When the respondent-Department has duly accepted all the contentions of the petitioner and found the e-way bills and computer generated measurement slip to be correct and genuine documents and the sole reason for initiating the proceedings against this petitioner and passing of the impugned adjudication orders was due to his transaction with M/s Jai Jawan Kastha Bhandar and M/s. Priti Enterprises and when the cases of those assesses have been remanded to the adjudicating authority to pass fresh order in accordance with law; interest of justice demands that the case of this petitioner should also be remitted back to the adjudicating authority, inasmuch as, the sole cause of action does not survives. - HC
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