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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Refund of excess availed/utilised Input Tax Credit - violation of Rule 36(4) of the CGST Rules, 2017 - Documentary proof of availing ITC - Belated filing of return - For the relevant period, though there is no extention of date of filing of GSTR Return, all that was done by means of subsequent Notifications was to waive/reduce late filing fee, interest, and penalty liabilities. - For the period to which the said proviso applies, the administrative instruction dated 11.11.2019 must survive in complete hibernation. Else, it may lose life to the higher statutory law. - HC
Refund of excess availed/utilised Input Tax Credit - violation of Rule 36(4) of the CGST Rules, 2017 - Documentary proof of availing ITC - Belated filing of return - For the relevant period, though there is no extention of date of filing of GSTR Return, all that was done by means of subsequent Notifications was to waive/reduce late filing fee, interest, and penalty liabilities. - For the period to which the said proviso applies, the administrative instruction dated 11.11.2019 must survive in complete hibernation. Else, it may lose life to the higher statutory law. - HC
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