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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Central Government notifies special procedure for rectification of orders issued u/ss 73, 74, 107, 108 confirming demand for wrong availment of input tax credit. Registered persons against whom such orders have been issued can file application electronically within six months for rectification if input tax credit is now available u/s 16(5) or 16(6), provided no appeal is pending. Application to include details of demand confirmed and eligible credit. Proper officer to decide on application and issue rectified order within three months. Rectification allowed only for credit wrongly denied u/s 16(4) but now admissible under 16(5) or 16(6). Principles of natural justice to be followed if rectification adversely affects the person. Prescribed proforma for filing application with declaration and verification.
Central Government notifies special procedure for rectification of orders issued u/ss 73, 74, 107, 108 confirming demand for wrong availment of input tax credit. Registered persons against whom such orders have been issued can file application electronically within six months for rectification if input tax credit is now available u/s 16(5) or 16(6), provided no appeal is pending. Application to include details of demand confirmed and eligible credit. Proper officer to decide on application and issue rectified order within three months. Rectification allowed only for credit wrongly denied u/s 16(4) but now admissible under 16(5) or 16(6). Principles of natural justice to be followed if rectification adversely affects the person. Prescribed proforma for filing application with declaration and verification.
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