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 case involves disputes u/s CST Act and KVAT Rules. The High Court addressed issues including whether a time gap exceeding 100 days between transit end and buyer lifting affects sale in export, treatment of stock transfer in export sales, proper apportionment methodology, and concessional tax rate eligibility. The Court held that the Tribunal erred in imposing the 100-day limit, stock transfer inclusion, and apportionment methodology. It remitted issues for reconsideration. The Court upheld the concessional tax rate for a vehicle sale but allowed penalty recomputation. The petition was partially allowed.
The case involves disputes u/s CST Act and KVAT Rules. The High Court addressed issues including whether a time gap exceeding 100 days between transit end and buyer lifting affects sale in export, treatment of stock transfer in export sales, proper apportionment methodology, and concessional tax rate eligibility. The Court held that the Tribunal erred in imposing the 100-day limit, stock transfer inclusion, and apportionment methodology. It remitted issues for reconsideration. The Court upheld the concessional tax rate for a vehicle sale but allowed penalty recomputation. The petition was partially allowed.
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