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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Carry forward of excess payment of tax as ITC for next year - Allegation of availment of excess input tax credit - . The appellant argued that the net tax payable for the previous year was in minus, indicating an excess tax payment that should be returned back and carried forward as Input Tax Credit for the next year. The High Court agreed with the appellant's argument and set aside the order passed by the Writ Court. The matter was remitted back to the revenue for reconsideration, with instructions to provide the appellant with an opportunity to present her case.
Carry forward of excess payment of tax as ITC for next year - Allegation of availment of excess input tax credit - . The appellant argued that the net tax payable for the previous year was in minus, indicating an excess tax payment that should be returned back and carried forward as Input Tax Credit for the next year. The High Court agreed with the appellant's argument and set aside the order passed by the Writ Court. The matter was remitted back to the revenue for reconsideration, with instructions to provide the appellant with an opportunity to present her case.
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