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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Harrasement or not - petitioner submitted that under the production of summons, the petitioner is forced to give an undertaking to pay the tax - The term harassment is so subjective which cannot be encapsulated in objective criterion. The petitioner having received summons from the respondent, is bound to cooperate for enquiry. Admittedly, the enquiry is pending. Without cooperating with the respondent, they cannot seek such a blanket direction. - HC
Harrasement or not - petitioner submitted that under the production of summons, the petitioner is forced to give an undertaking to pay the tax - The term harassment is so subjective which cannot be encapsulated in objective criterion. The petitioner having received summons from the respondent, is bound to cooperate for enquiry. Admittedly, the enquiry is pending. Without cooperating with the respondent, they cannot seek such a blanket direction. - HC
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