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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Lack of mention regarding tax demand in the show cause notice - Apparent discrepancy in treatment of refund claim and tax demand. - Scope for granting interim order on the writ petition - The Court observed that there was no error in the order passed by the learned Single Bench, which refused to grant interim relief on the writ petition. As of the date of the appeal, no demand notice had been issued to the appellant by the concerned authority. Therefore, the appeal was disposed of with the liberty granted to the appellant to file a fresh stay application before the learned Single Bench once a demand notice is issued.
Lack of mention regarding tax demand in the show cause notice - Apparent discrepancy in treatment of refund claim and tax demand. - Scope for granting interim order on the writ petition - The Court observed that there was no error in the order passed by the learned Single Bench, which refused to grant interim relief on the writ petition. As of the date of the appeal, no demand notice had been issued to the appellant by the concerned authority. Therefore, the appeal was disposed of with the liberty granted to the appellant to file a fresh stay application before the learned Single Bench once a demand notice is issued.
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