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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As per the Scheme of Amalgamation, the effective merger date of the petitioner company with another company was 01.04.2012. Post-merger, the petitioner ceased to exist, and its tax liability merged with the transferee company. The transferee was obligated to include the transferor's tax liability. Issuing assessment orders against the non-existent transferor post-merger was incorrect. The impugned assessment orders were quashed, and the writ petitions were allowed by the HC.
As per the Scheme of Amalgamation, the effective merger date of the petitioner company with another company was 01.04.2012. Post-merger, the petitioner ceased to exist, and its tax liability merged with the transferee company. The transferee was obligated to include the transferor's tax liability. Issuing assessment orders against the non-existent transferor post-merger was incorrect. The impugned assessment orders were quashed, and the writ petitions were allowed by the HC.
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