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 considered the validity of proceedings u/s 144BA regarding issuance of bonus shares and the invocation of GAAR over SAAR. The petitioner sought to set off short term capital loss against long term gains, questioning the application of Section 94(8) vs. GAAR. The court noted GAAR's overriding effect u/s 95(1) and rejected petitioner's argument favoring SAAR. The court found the arrangement lacked commercial substance, falling u/s 96 of Chapter X-A. The petitioner's reliance on the Shome Committee Report was deemed misplaced. The court emphasized fair tax planning within the law and dismissed the writ petitions, allowing proceedings u/s 144AB to continue.
The High Court considered the validity of proceedings u/s 144BA regarding issuance of bonus shares and the invocation of GAAR over SAAR. The petitioner sought to set off short term capital loss against long term gains, questioning the application of Section 94(8) vs. GAAR. The court noted GAAR's overriding effect u/s 95(1) and rejected petitioner's argument favoring SAAR. The court found the arrangement lacked commercial substance, falling u/s 96 of Chapter X-A. The petitioner's reliance on the Shome Committee Report was deemed misplaced. The court emphasized fair tax planning within the law and dismissed the writ petitions, allowing proceedings u/s 144AB to continue.
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