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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The High Court examined the constitutionality of u/s 16(2)(c) and 16(4) of the CGST/SGST Act regarding Input Tax Credit (ITC) restrictions. The Court held that the legislation was valid as it falls u/s Article 246A and serves public purposes. The claim for ITC is a concession, not an absolute right, subject to statutory conditions. The restrictions on ITC time limits were deemed necessary for revenue balance. The Court rejected challenges to the constitutionality of the sections, emphasizing the importance of statutory restrictions. The Court granted partial relief for 2017-18 and 2018-19, allowing for the refund of unutilized ITC and extending the time limit for filing annual returns.
The High Court examined the constitutionality of u/s 16(2)(c) and 16(4) of the CGST/SGST Act regarding Input Tax Credit (ITC) restrictions. The Court held that the legislation was valid as it falls u/s Article 246A and serves public purposes. The claim for ITC is a concession, not an absolute right, subject to statutory conditions. The restrictions on ITC time limits were deemed necessary for revenue balance. The Court rejected challenges to the constitutionality of the sections, emphasizing the importance of statutory restrictions. The Court granted partial relief for 2017-18 and 2018-19, allowing for the refund of unutilized ITC and extending the time limit for filing annual returns.
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