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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Imposition of costs on the Department - provisional attachment - a fine question of law has been raised by the assesses in their appeal arising out of the very same common order and the present appeals filed by the Revenue is confined only to that extent where cost has been imposed. Therefore, in the facts and circumstances of the case, we are of the view that it is not a case where cost has to be imposed, as directed by the learned writ Court. - HC
Imposition of costs on the Department - provisional attachment - a fine question of law has been raised by the assesses in their appeal arising out of the very same common order and the present appeals filed by the Revenue is confined only to that extent where cost has been imposed. Therefore, in the facts and circumstances of the case, we are of the view that it is not a case where cost has to be imposed, as directed by the learned writ Court. - HC
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