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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Rejection of application for Advance Ruling - Levy of GST - The appellate authority observed that the rejection of the advance ruling application was based on the investigation initiated by DGGI. The rejection did not consider the GST applicability issue directly. - The authority found that the rejection of the application lacked procedural fairness. The appellant was not provided with materials and comments forwarded by DGGI, depriving them of the opportunity to respond. Consequently, the case was remanded to the lower authority for reconsideration while ensuring the appellant's right to a fair hearing.
Rejection of application for Advance Ruling - Levy of GST - The appellate authority observed that the rejection of the advance ruling application was based on the investigation initiated by DGGI. The rejection did not consider the GST applicability issue directly. - The authority found that the rejection of the application lacked procedural fairness. The appellant was not provided with materials and comments forwarded by DGGI, depriving them of the opportunity to respond. Consequently, the case was remanded to the lower authority for reconsideration while ensuring the appellant's right to a fair hearing.
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