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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Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 - SVLDRS - adjustment of amount deposited under protect - The issues with regard to the liability of the respondent towards duty and interest were at large and the amounts were already deposited when the scheme came into force. The circular issued by the Central Board of Indirect Taxes and Customs relied upon by the respondent also clearly shows that the department was liable to adjust the entire amount deposited by the assessee under protest prior to the adjudication of the liability either towards Central Excise Duty or towards the interest. - HC
Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 - SVLDRS - adjustment of amount deposited under protect - The issues with regard to the liability of the respondent towards duty and interest were at large and the amounts were already deposited when the scheme came into force. The circular issued by the Central Board of Indirect Taxes and Customs relied upon by the respondent also clearly shows that the department was liable to adjust the entire amount deposited by the assessee under protest prior to the adjudication of the liability either towards Central Excise Duty or towards the interest. - HC
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