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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Respondent M/s Vedanta Limited [Vedanta] is the resultant entity after M/s Cairn India Limited [Cairn] amalgamated with it. The TPO and AO inadvertently made the draft assessment order in the name of the non-existent Cairn instead of Vedanta, despite being apprised of the merger. The HC held that framing an order against a non-existent entity is a fatal flaw which cannot be rectified u/s 292B or Section 154 of the Act, following the Supreme Court's decision in Maruti Suzuki. The facts were distinguished from Sky Light, where the assessee's conduct led the SC to uphold the assessment despite being in the name of a non-existent entity. The HC found no merit in the revenue's argument and decided against it.
Respondent M/s Vedanta Limited [Vedanta] is the resultant entity after M/s Cairn India Limited [Cairn] amalgamated with it. The TPO and AO inadvertently made the draft assessment order in the name of the non-existent Cairn instead of Vedanta, despite being apprised of the merger. The HC held that framing an order against a non-existent entity is a fatal flaw which cannot be rectified u/s 292B or Section 154 of the Act, following the Supreme Court's decision in Maruti Suzuki. The facts were distinguished from Sky Light, where the assessee's conduct led the SC to uphold the assessment despite being in the name of a non-existent entity. The HC found no merit in the revenue's argument and decided against it.
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