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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Interest on Refund - claim of interest from the date of encashment of bank guarantees till grant of refund - The 3rd respondent has committed an error in recording an erroneous finding that the aforesaid amount encashed under the bank guarantees was available with the petitioner during the aforesaid period from 29.03.2019 till 05.01.2022; this finding recorded by the 3rd respondent in the impugned order is clearly and factually incorrect and contrary to the material on record - interest to be allowed @6% - HC
Interest on Refund - claim of interest from the date of encashment of bank guarantees till grant of refund - The 3rd respondent has committed an error in recording an erroneous finding that the aforesaid amount encashed under the bank guarantees was available with the petitioner during the aforesaid period from 29.03.2019 till 05.01.2022; this finding recorded by the 3rd respondent in the impugned order is clearly and factually incorrect and contrary to the material on record - interest to be allowed @6% - HC
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