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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Charge created by Sales Tax Department over property subsequent to charge created by bank under SARFAESI Act held unsustainable. HC quashed charge created by Sales Tax Department in 2018 over property already sold by bank to petitioners under SARFAESI Act, directing removal of charge and deletion of mutation entries in revenue records, as bank's prior charge took precedence as per legal position. Petition disposed of.
Charge created by Sales Tax Department over property subsequent to charge created by bank under SARFAESI Act held unsustainable. HC quashed charge created by Sales Tax Department in 2018 over property already sold by bank to petitioners under SARFAESI Act, directing removal of charge and deletion of mutation entries in revenue records, as bank's prior charge took precedence as per legal position. Petition disposed of.
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