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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Penalty order - wrongful mention of place of supply in E-Way bills - intent to evade tax or not - The High Court noted that the incorrect address mentioned in the E-Way bills was the registered office of the petitioner, suggesting a technical or clerical error rather than an intentional attempt to evade tax. - The court concludes that since most documents were accompanied with the goods and only some E-Way bills contained errors, with correct addresses mentioned elsewhere, no presumption of tax evasion arises. - Consequently, the penalty orders quashed and set aside.
Penalty order - wrongful mention of place of supply in E-Way bills - intent to evade tax or not - The High Court noted that the incorrect address mentioned in the E-Way bills was the registered office of the petitioner, suggesting a technical or clerical error rather than an intentional attempt to evade tax. - The court concludes that since most documents were accompanied with the goods and only some E-Way bills contained errors, with correct addresses mentioned elsewhere, no presumption of tax evasion arises. - Consequently, the penalty orders quashed and set aside.
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