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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Cancellation of GST registration - violation of Section 29(2)(a) of Central Goods and Services Tax Act, 2017. Respondent no. 2 is the proper authority to inquire about cancellation or suspension of GST registration and pass necessary orders. Although a notice might have been issued under an erroneous provision, petitioner no. 1 has liberty to reply, raise jurisdictional issues, and request amendments. Respondent no. 2 can initiate appropriate proceedings if petitioner no. 1 shows the provision invoked is incorrect. Only a show cause notice has been issued seeking clarification and documents from petitioner no. 1. Authorities must hear the party and pass orders per law. Premature for the High Court to interfere at this stage. Petition disposed of.
Cancellation of GST registration - violation of Section 29(2)(a) of Central Goods and Services Tax Act, 2017. Respondent no. 2 is the proper authority to inquire about cancellation or suspension of GST registration and pass necessary orders. Although a notice might have been issued under an erroneous provision, petitioner no. 1 has liberty to reply, raise jurisdictional issues, and request amendments. Respondent no. 2 can initiate appropriate proceedings if petitioner no. 1 shows the provision invoked is incorrect. Only a show cause notice has been issued seeking clarification and documents from petitioner no. 1. Authorities must hear the party and pass orders per law. Premature for the High Court to interfere at this stage. Petition disposed of.
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