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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Violation of the principles of natural justice - Validity of GST assessment order - it is the case of increase in GST from 12% to 18% for works contract executed for the government department and local bodies. Even though the petitioner is liable to pay GST, but ultimately it is the Government and the Local Bodies has to pay the GST and the petitioner is entitled to pay and recover from the government. Hence, the ultimate sufferer is the Government. - Matter restored back - HC
Violation of the principles of natural justice - Validity of GST assessment order - it is the case of increase in GST from 12% to 18% for works contract executed for the government department and local bodies. Even though the petitioner is liable to pay GST, but ultimately it is the Government and the Local Bodies has to pay the GST and the petitioner is entitled to pay and recover from the government. Hence, the ultimate sufferer is the Government. - Matter restored back - HC
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