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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Resumption of seized cash/currency u/s 67 of CGST Act - Scope and definition of "goods / things" - cash was sale proceeds of unaccounted goods or not - The High court concludes that cash cannot be considered among the "things" subject to seizure under Section 67(2) of the CGST Act. - Furthermore, the court finds that there is no evidence to support the seizure of the cash as representing the sale proceeds of unaccounted goods, as required by the Act. - The action taken by the Officers was therefore a coercive action. CGST Act does not support such an action of forcibly taking over the possession of the currency from the premises of any person. - The amount directed to be released to the petitioner forthwith.
Resumption of seized cash/currency u/s 67 of CGST Act - Scope and definition of "goods / things" - cash was sale proceeds of unaccounted goods or not - The High court concludes that cash cannot be considered among the "things" subject to seizure under Section 67(2) of the CGST Act. - Furthermore, the court finds that there is no evidence to support the seizure of the cash as representing the sale proceeds of unaccounted goods, as required by the Act. - The action taken by the Officers was therefore a coercive action. CGST Act does not support such an action of forcibly taking over the possession of the currency from the premises of any person. - The amount directed to be released to the petitioner forthwith.
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