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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Validity of assessment orders under GST - Transitional credit eligibility - Petitioner had obtained GST registrations in the names of its employees for the unlawful purpose of availing of ITC - Violation of principles of natural justice - The High Court held that, the principles of natural justice cannot be put into a straight jacket. - The said order was in inquiry proceedings pursuant to a charge memo and cannot be compared to assessment proceedings. It should be borne in mind that the obligation of establishing eligibility for ITC is cast on the assessee concerned and, therefore, it is the responsibility of the assessee to place all the material documents to establish the actual purchase and receipt of goods or services.
Validity of assessment orders under GST - Transitional credit eligibility - Petitioner had obtained GST registrations in the names of its employees for the unlawful purpose of availing of ITC - Violation of principles of natural justice - The High Court held that, the principles of natural justice cannot be put into a straight jacket. - The said order was in inquiry proceedings pursuant to a charge memo and cannot be compared to assessment proceedings. It should be borne in mind that the obligation of establishing eligibility for ITC is cast on the assessee concerned and, therefore, it is the responsibility of the assessee to place all the material documents to establish the actual purchase and receipt of goods or services.
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