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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Recovery of dues (commercial tax arrears) - purchase of property through public auction - The burden rests upon the revenue to establish that the consideration for the property is inadequate, that the vendor had due notice of the pendency of the sales tax proceedings and the transfer itself, was a measure to evade tax. In the present case, the parties, that is, the petitioner and the defaulting assessee are admittedly unrelated and the transaction of purchase is bonafide - HC
Recovery of dues (commercial tax arrears) - purchase of property through public auction - The burden rests upon the revenue to establish that the consideration for the property is inadequate, that the vendor had due notice of the pendency of the sales tax proceedings and the transfer itself, was a measure to evade tax. In the present case, the parties, that is, the petitioner and the defaulting assessee are admittedly unrelated and the transaction of purchase is bonafide - HC
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