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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Ceasure of income tax settlement commission - restriction to the filing of the application before the Interim Board for Settlement - The Court found that the retrospective legislative changes could not negate the petitioner's vested rights to file a settlement application, particularly when such applications were made before the enactment of the Finance Act, 2021. It was held that the administrative actions and notifications that imposed additional eligibility criteria, not rooted in the Act, were invalid. - The Court quashed the contested notice and notification, directing that the petitioner's application be considered and disposed of in accordance with the law.
Ceasure of income tax settlement commission - restriction to the filing of the application before the Interim Board for Settlement - The Court found that the retrospective legislative changes could not negate the petitioner's vested rights to file a settlement application, particularly when such applications were made before the enactment of the Finance Act, 2021. It was held that the administrative actions and notifications that imposed additional eligibility criteria, not rooted in the Act, were invalid. - The Court quashed the contested notice and notification, directing that the petitioner's application be considered and disposed of in accordance with the law.
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