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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Cancellation of GST registration of the petitioner - Rule 22 (3) of CER - The court examines the validity of the show cause notice issued by the respondent and considers the petitioner's argument regarding the ex-parte physical verification. It emphasizes the need for adherence to Rule 25 of the Central Goods and Service Tax Rules, 2017, regarding the conduct of such verifications. - The court interprets Rule 22(3) of the Rules, which stipulates a timeframe for issuing an order in response to a show cause notice. It concludes that the provision is directory rather than mandatory, as there are no specified consequences for non-compliance within the stipulated timeframe.
Cancellation of GST registration of the petitioner - Rule 22 (3) of CER - The court examines the validity of the show cause notice issued by the respondent and considers the petitioner's argument regarding the ex-parte physical verification. It emphasizes the need for adherence to Rule 25 of the Central Goods and Service Tax Rules, 2017, regarding the conduct of such verifications. - The court interprets Rule 22(3) of the Rules, which stipulates a timeframe for issuing an order in response to a show cause notice. It concludes that the provision is directory rather than mandatory, as there are no specified consequences for non-compliance within the stipulated timeframe.
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