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 held that the Interim Board for Settlement erred in rejecting the petitioner's settlement application for the relevant assessment years based on the condition in the CBDT notification that the assessee should be eligible on January 21, 2021. The court relied on its previous decision in Sar Senapati Santaji Ghorpade Sugar Factory Ltd., which quashed the said condition as ultra vires Section 119. Following this precedent and its recent decision in M/s. Vishwakarma Developers, the court allowed the present proceedings and quashed the orders passed by the Interim Settlement Board rejecting the petitioner's application.
The High Court held that the Interim Board for Settlement erred in rejecting the petitioner's settlement application for the relevant assessment years based on the condition in the CBDT notification that the assessee should be eligible on January 21, 2021. The court relied on its previous decision in Sar Senapati Santaji Ghorpade Sugar Factory Ltd., which quashed the said condition as ultra vires Section 119. Following this precedent and its recent decision in M/s. Vishwakarma Developers, the court allowed the present proceedings and quashed the orders passed by the Interim Settlement Board rejecting the petitioner's application.
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