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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Rejection of Form SVLDRS-1 - valid quantification and admission of duty/tax by Petitioner before 30th June, 2019 - Section 125 of the Finance Act, 2019 provides that all persons are eligible to make a declaration under the SVLDRS scheme with the exception of those falling within the exceptions set out in clauses (a) to (h) of sub-section (1) of Section 125. 'Tax dues' referred in section 124 is defined in section 123. It specifies various situations - The Respondent No.4 was completely unjustified in rejecting the Form SVLDRS-1 filed by Petitioner - HC
Rejection of Form SVLDRS-1 - valid quantification and admission of duty/tax by Petitioner before 30th June, 2019 - Section 125 of the Finance Act, 2019 provides that all persons are eligible to make a declaration under the SVLDRS scheme with the exception of those falling within the exceptions set out in clauses (a) to (h) of sub-section (1) of Section 125. 'Tax dues' referred in section 124 is defined in section 123. It specifies various situations - The Respondent No.4 was completely unjustified in rejecting the Form SVLDRS-1 filed by Petitioner - HC
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