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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Interest on Delayed Refund of Input Tax Credit - Proviso to Section 56 specified increased interest rates for refunds arising from orders of adjudicating or appellate authorities. - The High court observed that the provision for interest in tax statutes is beneficial and non-discriminatory. - Non-granting of interest would constitute a failure to fulfill statutory obligation by the refund sanctioning authority. - The High Court highlighted the principle of strict construction of fiscal legislation and the necessity for interest payment. - Ultimately, the court directed the respondents to pay interest on the delayed refunds to the petitioners.
Interest on Delayed Refund of Input Tax Credit - Proviso to Section 56 specified increased interest rates for refunds arising from orders of adjudicating or appellate authorities. - The High court observed that the provision for interest in tax statutes is beneficial and non-discriminatory. - Non-granting of interest would constitute a failure to fulfill statutory obligation by the refund sanctioning authority. - The High Court highlighted the principle of strict construction of fiscal legislation and the necessity for interest payment. - Ultimately, the court directed the respondents to pay interest on the delayed refunds to the petitioners.
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