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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Reversal of input tax credit - The High court found no merit in the petitioner's challenge to the constitutional validity of the fiscal legislation, as the petitioner failed to demonstrate any violation of constitutional provisions. The court also noted that the registration of the selling dealer had been cancelled before the purchase, meaning the seller had not paid tax, thus negating the petitioner's claim of double taxation.
Reversal of input tax credit - The High court found no merit in the petitioner's challenge to the constitutional validity of the fiscal legislation, as the petitioner failed to demonstrate any violation of constitutional provisions. The court also noted that the registration of the selling dealer had been cancelled before the purchase, meaning the seller had not paid tax, thus negating the petitioner's claim of double taxation.
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