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 HC quashed the reassessment proceedings for AYs 2013-14 to 2017-18, holding that the findings from surveys conducted in 2007 and 2019 could not be blindly adopted to determine existence of a PE for those years. The HC reiterated that the position of a PE is fact-specific and requires examination of the prevailing facts for each tax period. The AO failed to demonstrate application of mind to the relevant facts and merely relied on earlier survey findings and court judgments. The HC emphasized that no principle akin to res judicata applies in tax matters and that consistency must be balanced against the facts of each assessment year.
The HC quashed the reassessment proceedings for AYs 2013-14 to 2017-18, holding that the findings from surveys conducted in 2007 and 2019 could not be blindly adopted to determine existence of a PE for those years. The HC reiterated that the position of a PE is fact-specific and requires examination of the prevailing facts for each tax period. The AO failed to demonstrate application of mind to the relevant facts and merely relied on earlier survey findings and court judgments. The HC emphasized that no principle akin to res judicata applies in tax matters and that consistency must be balanced against the facts of each assessment year.
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