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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Recovery of Service Tax dues, of a Company which is under liquidation applying IBC, 2016 - It is thus beyond the two years preceding the commencement of liquidation date and the Company having been liquidated and the respondent having failed to lodge any claim under IBC at any stage of the proceeding under IBC and the sale proceeds having been distributed in terms of the waterfall it may not be permissible to sustain the impugned demand notice. - HC
Recovery of Service Tax dues, of a Company which is under liquidation applying IBC, 2016 - It is thus beyond the two years preceding the commencement of liquidation date and the Company having been liquidated and the respondent having failed to lodge any claim under IBC at any stage of the proceeding under IBC and the sale proceeds having been distributed in terms of the waterfall it may not be permissible to sustain the impugned demand notice. - HC
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