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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Benefit of the provisions of the DTVSV Act - The High court found that, it is true that the DTVSV Act is having the object of resolution of the disputed tax, however, the same cannot be made available to the assessees whose appeals are not pending on the specified date. If the application filed by the petitioner is ordered to be entertained, then the statutory provisions of the DTSVS Act would be rendered nugatory and appeal which was filed subsequently cannot being the case of the petitioner within the scope of provision of DTVSV Act. Petition dismissed.
Benefit of the provisions of the DTVSV Act - The High court found that, it is true that the DTVSV Act is having the object of resolution of the disputed tax, however, the same cannot be made available to the assessees whose appeals are not pending on the specified date. If the application filed by the petitioner is ordered to be entertained, then the statutory provisions of the DTSVS Act would be rendered nugatory and appeal which was filed subsequently cannot being the case of the petitioner within the scope of provision of DTVSV Act. Petition dismissed.
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