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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Challenge to summary order passed against the petitioner u/s 74 - The court rejected the petitioner's claim of not being granted a personal hearing, stating that the petitioner was indeed given opportunities for personal hearing, which they did not avail themselves of. The court also noted that the impugned order considered the replies filed by the petitioner. - However, the court acknowledged the petitioner's partial relief by permitting them to file a statutory appeal before the Appellate Authority within 30 days, subject to pre-depositing the amount as contemplated under Section 107 of the TNGST Act, 2017.
Challenge to summary order passed against the petitioner u/s 74 - The court rejected the petitioner's claim of not being granted a personal hearing, stating that the petitioner was indeed given opportunities for personal hearing, which they did not avail themselves of. The court also noted that the impugned order considered the replies filed by the petitioner. - However, the court acknowledged the petitioner's partial relief by permitting them to file a statutory appeal before the Appellate Authority within 30 days, subject to pre-depositing the amount as contemplated under Section 107 of the TNGST Act, 2017.
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