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 SCN - delivery of notices beyond the time limitation - the notice was served on them by hand on 03.04.2001. In such circumstances, the service of notice effected on the petitioner at the first instance itself, would be deemed to be completed service and hence, the question of affixing the notice in the notice board of the customs house, will not arise. Therefore, this court is of the view that if the date of despatch of notices is taken into consideration, the notices served on the petitioner are within the period of limitation. - HC
Validity of SCN - delivery of notices beyond the time limitation - the notice was served on them by hand on 03.04.2001. In such circumstances, the service of notice effected on the petitioner at the first instance itself, would be deemed to be completed service and hence, the question of affixing the notice in the notice board of the customs house, will not arise. Therefore, this court is of the view that if the date of despatch of notices is taken into consideration, the notices served on the petitioner are within the period of limitation. - HC
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