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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Violation of principles of natural justice - cryptic order - excess claim Input Tax Credit - Despite the petitioner submitting a detailed reply, the court found that the impugned order failed to adequately consider their response. The court noted deficiencies in the order's assessment of the petitioner's submissions and its failure to seek clarifications if deemed necessary. Consequently, the High Court set aside the order and remitted the matter for re-adjudication, directing the Proper Officer to provide specific details or documents required from the petitioner. The court reserved its consideration on the merits of the case and left open the challenge to a specific notification.
Violation of principles of natural justice - cryptic order - excess claim Input Tax Credit - Despite the petitioner submitting a detailed reply, the court found that the impugned order failed to adequately consider their response. The court noted deficiencies in the order's assessment of the petitioner's submissions and its failure to seek clarifications if deemed necessary. Consequently, the High Court set aside the order and remitted the matter for re-adjudication, directing the Proper Officer to provide specific details or documents required from the petitioner. The court reserved its consideration on the merits of the case and left open the challenge to a specific notification.
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