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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Calculation of Tax Liability based on subsequent year's Balance Sheet - non-service of SCN - Obligation to monitor GST Portal - The High Court found merit in the petitioner's argument regarding the incorrect use of financial statements for the assessment period. It noted that the respondent should have utilized the 2017-2018 balance sheet for adjudication, rather than the subsequent year's balance sheet. - While acknowledging the petitioner's obligation to monitor the GST portal regularly, the court emphasized the need for proper communication of official notices. However, it also held the petitioner accountable for not responding to the notice within the stipulated period. - Matter restored back, subject to remit a specified sum as a condition for remand.
Calculation of Tax Liability based on subsequent year's Balance Sheet - non-service of SCN - Obligation to monitor GST Portal - The High Court found merit in the petitioner's argument regarding the incorrect use of financial statements for the assessment period. It noted that the respondent should have utilized the 2017-2018 balance sheet for adjudication, rather than the subsequent year's balance sheet. - While acknowledging the petitioner's obligation to monitor the GST portal regularly, the court emphasized the need for proper communication of official notices. However, it also held the petitioner accountable for not responding to the notice within the stipulated period. - Matter restored back, subject to remit a specified sum as a condition for remand.
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