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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Blocked input tax credit - issuance of credit notes by the supplier - denial of Input Tax Credit with regard to certain inputs - Both parties presented their arguments, with the petitioner emphasizing the provision of evidence supporting their claims. The Court found discrepancies in the assessing officer's conclusions and noted the lack of explicit reasons for denying Input Tax Credit. Consequently, the impugned order was set aside on all three issues and remanded for re-consideration, with directions for providing the petitioner with a reasonable opportunity to present their case.
Blocked input tax credit - issuance of credit notes by the supplier - denial of Input Tax Credit with regard to certain inputs - Both parties presented their arguments, with the petitioner emphasizing the provision of evidence supporting their claims. The Court found discrepancies in the assessing officer's conclusions and noted the lack of explicit reasons for denying Input Tax Credit. Consequently, the impugned order was set aside on all three issues and remanded for re-consideration, with directions for providing the petitioner with a reasonable opportunity to present their case.
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