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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Levy of Sales Tax / VAT - deemed export to DTA - units in SEZs - A declaration is sought to extend the benefit contrary to the Statute (i.e., KVAT), and the declaration could be over and above what is accepted as a Policy by the State Legislature in Section 6(7)(b) read with Section 32(1). The declaration could be a singular instance under the Act despite attracting the incidence of liability for the sales made to DTA, still, the petitioner could be allowed to have the exemption from payment of tax.- HC
Levy of Sales Tax / VAT - deemed export to DTA - units in SEZs - A declaration is sought to extend the benefit contrary to the Statute (i.e., KVAT), and the declaration could be over and above what is accepted as a Policy by the State Legislature in Section 6(7)(b) read with Section 32(1). The declaration could be a singular instance under the Act despite attracting the incidence of liability for the sales made to DTA, still, the petitioner could be allowed to have the exemption from payment of tax.- HC
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