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 petitioner's case falls under "amount in arrears" category under SVLDRS, not "litigation" category, as no appeal was filed before 30.06.2019 against Order-in-original demanding Rs. 32,27,856/-. Designated committee's mechanical issuance of Form SVLDRS-3 without considering petitioner's reply demonstrated non-application of mind. Petitioner, having already deposited 60% of tax arrears (Rs. 31,32,551.60), is entitled to relief u/s 124 of SVLDRS. Court set aside committee's demand for higher amount and allowed petition, affirming petitioner's eligibility for reduced tax liability under scheme's provisions for arrears category.
HC determined petitioner's case falls under "amount in arrears" category under SVLDRS, not "litigation" category, as no appeal was filed before 30.06.2019 against Order-in-original demanding Rs. 32,27,856/-. Designated committee's mechanical issuance of Form SVLDRS-3 without considering petitioner's reply demonstrated non-application of mind. Petitioner, having already deposited 60% of tax arrears (Rs. 31,32,551.60), is entitled to relief u/s 124 of SVLDRS. Court set aside committee's demand for higher amount and allowed petition, affirming petitioner's eligibility for reduced tax liability under scheme's provisions for arrears category.
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