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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Extension of period for issuance of show cause notice u/s 73 of GST Act, 2017 - Validity of N/N. 09/2023 - The Hich Court noted that the Notification extends the time limit under Section 73(10) of the CGST Act, attributing the extension to the COVID-19 pandemic as a force majeure event. - The court acknowledges previous extensions of the time limit and the interim reliefs granted by other High Courts to noticees facing similar situations. - The court allows proceedings to continue on the Show Cause Notice but prohibits the passing of a final order until the returnable date.
Extension of period for issuance of show cause notice u/s 73 of GST Act, 2017 - Validity of N/N. 09/2023 - The Hich Court noted that the Notification extends the time limit under Section 73(10) of the CGST Act, attributing the extension to the COVID-19 pandemic as a force majeure event. - The court acknowledges previous extensions of the time limit and the interim reliefs granted by other High Courts to noticees facing similar situations. - The court allows proceedings to continue on the Show Cause Notice but prohibits the passing of a final order until the returnable date.
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