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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Garnishee order - long delay of about more than a year in filing these writ petitions - The High Court acknowledged the substantial delay in filing the writ petitions. Despite the petitioner's argument that the impugned orders of garnishee were appealable under statute, the Court emphasized the importance of adhering to statutory timelines. Consequently, the Court was disinclined to grant relief to the petitioner due to the inordinate delay. Instead, the Court denied relief to the petitioner but allowed them to file appeals under certain conditions. These conditions included making a pre-deposit in each appeal, paying a cost of Rs. 1 lakh for delays.
Garnishee order - long delay of about more than a year in filing these writ petitions - The High Court acknowledged the substantial delay in filing the writ petitions. Despite the petitioner's argument that the impugned orders of garnishee were appealable under statute, the Court emphasized the importance of adhering to statutory timelines. Consequently, the Court was disinclined to grant relief to the petitioner due to the inordinate delay. Instead, the Court denied relief to the petitioner but allowed them to file appeals under certain conditions. These conditions included making a pre-deposit in each appeal, paying a cost of Rs. 1 lakh for delays.
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