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 circular addresses the Reduction of Government Litigation by setting monetary limits for filing appeals before GSTAT, High Courts, and Supreme Court. It refers to the National Litigation Policy, emphasizing prudent litigation practices. The circular cites Section 120 of the CGST Act, empowering the Central Board of Indirect Taxes & Customs to fix monetary limits for appeals. The circular sets monetary limits for filing appeals: GSTAT - 20,00,000/-, High Court - 1,00,00,000/-, and Supreme Court - 2,00,00,000/-. It outlines principles for determining if a case falls within these limits and specifies exclusions where monetary limits do not apply. It highlights that filing an appeal should be based on case merits, not just exceeding monetary limits, to reduce unnecessary litigation. Non-filing of appeals based on monetary limits does not set a precedent value. The circular encourages officers to decide on appeals based on reducing litigation and providing certainty to taxpayers.
The circular addresses the Reduction of Government Litigation by setting monetary limits for filing appeals before GSTAT, High Courts, and Supreme Court. It refers to the National Litigation Policy, emphasizing prudent litigation practices. The circular cites Section 120 of the CGST Act, empowering the Central Board of Indirect Taxes & Customs to fix monetary limits for appeals. The circular sets monetary limits for filing appeals: GSTAT - 20,00,000/-, High Court - 1,00,00,000/-, and Supreme Court - 2,00,00,000/-. It outlines principles for determining if a case falls within these limits and specifies exclusions where monetary limits do not apply. It highlights that filing an appeal should be based on case merits, not just exceeding monetary limits, to reduce unnecessary litigation. Non-filing of appeals based on monetary limits does not set a precedent value. The circular encourages officers to decide on appeals based on reducing litigation and providing certainty to taxpayers.
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