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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SVLDRS - etermination of tax - The stance taken by the Department in relying upon the SCN for determining the tax dues at Rs. 1.34 Crores is contrary to its stand before the CESTAT, wherein it accepted the determination of tax dues at Rs. 1.11 Crores - The inconsistency of the stance of the Department is further evident from the fact that if the appeal had been pending when the Scheme was announced the Petitioner’s tax dues would have been admittedly, determined by the Respondent as per the order-in-original and not SCN. - The determination of tax by the Designated Committee in Form No. SVLDRS-3 is set aside. - HC
SVLDRS - etermination of tax - The stance taken by the Department in relying upon the SCN for determining the tax dues at Rs. 1.34 Crores is contrary to its stand before the CESTAT, wherein it accepted the determination of tax dues at Rs. 1.11 Crores - The inconsistency of the stance of the Department is further evident from the fact that if the appeal had been pending when the Scheme was announced the Petitioner’s tax dues would have been admittedly, determined by the Respondent as per the order-in-original and not SCN. - The determination of tax by the Designated Committee in Form No. SVLDRS-3 is set aside. - HC
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