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 show cause notice - Levy of Interest - jurisdiction or authority of law under Section 50 of the KGST Act, to levy interest - The petitioner has been merely called upon to show cause as to why the amounts, penalty, interest etc., has detailed in the audit report should not be levied upon him. The said SCN also provides an opportunity for personal hearing to the petitioner and who also be entitled to produce pleadings and documents in support of his claim along with the reply to the show cause notice. - petitioner directed to submit his reply/response to the aforesaid SCN - HC
Validity of show cause notice - Levy of Interest - jurisdiction or authority of law under Section 50 of the KGST Act, to levy interest - The petitioner has been merely called upon to show cause as to why the amounts, penalty, interest etc., has detailed in the audit report should not be levied upon him. The said SCN also provides an opportunity for personal hearing to the petitioner and who also be entitled to produce pleadings and documents in support of his claim along with the reply to the show cause notice. - petitioner directed to submit his reply/response to the aforesaid SCN - HC
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