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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HC determined that certificates and orders demanding elevated tax amounts from the petitioner under Direct Tax Vivad Se Vishwas Act, 2020 were unlawful and arbitrary. The demands contravened both documentary evidence and statutory provisions of DTVSV Act. The court found no sustainable basis for the inflated tax assessment and concluded that the respondents' actions exceeded their jurisdictional authority under the tax dispute resolution framework. Accordingly, the orders were quashed, with specific directives issued to the respondents for compliance. The appeal against the petitioner's position was dismissed for lack of substantive merit, affirming the principle that tax demands must align with documentary evidence and statutory parameters.
HC determined that certificates and orders demanding elevated tax amounts from the petitioner under Direct Tax Vivad Se Vishwas Act, 2020 were unlawful and arbitrary. The demands contravened both documentary evidence and statutory provisions of DTVSV Act. The court found no sustainable basis for the inflated tax assessment and concluded that the respondents' actions exceeded their jurisdictional authority under the tax dispute resolution framework. Accordingly, the orders were quashed, with specific directives issued to the respondents for compliance. The appeal against the petitioner's position was dismissed for lack of substantive merit, affirming the principle that tax demands must align with documentary evidence and statutory parameters.
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