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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Prosecution u/s 276CC - Settlement Commission has already granted immunity from prosecution to the petitioner - The High Court highlighted the importance of the Settlement Commission's decision and its finality once not challenged by the Income Tax Authorities. - The Court found merit in the petitioner's arguments, emphasizing compliance with relevant notices and the finality of the Settlement Commission's decision. Drawing from precedent, the Court concluded that continuing the complaint would constitute a misuse of the legal process and hence quashed the proceedings.
Prosecution u/s 276CC - Settlement Commission has already granted immunity from prosecution to the petitioner - The High Court highlighted the importance of the Settlement Commission's decision and its finality once not challenged by the Income Tax Authorities. - The Court found merit in the petitioner's arguments, emphasizing compliance with relevant notices and the finality of the Settlement Commission's decision. Drawing from precedent, the Court concluded that continuing the complaint would constitute a misuse of the legal process and hence quashed the proceedings.
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