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 affirmed penalty under Section 10A of CST Act for misuse of C-Forms. Assessee purchased construction materials claiming concessional tax rates but failed to demonstrate integral connection to manufacturing process. Court held that concessional rates under Section 8(3)(b) apply only when goods listed in Registration Certificate are used for manufacturing or resale. Building materials used for office construction do not qualify for concession. Assessee's failure to prove goods' direct connection to production process violated statutory requirements. HC dismissed appeal, upholding Joint Commissioner's order imposing penalty, emphasizing strict compliance with Registration Certificate specifications for concessional tax eligibility.
HC affirmed penalty under Section 10A of CST Act for misuse of C-Forms. Assessee purchased construction materials claiming concessional tax rates but failed to demonstrate integral connection to manufacturing process. Court held that concessional rates under Section 8(3)(b) apply only when goods listed in Registration Certificate are used for manufacturing or resale. Building materials used for office construction do not qualify for concession. Assessee's failure to prove goods' direct connection to production process violated statutory requirements. HC dismissed appeal, upholding Joint Commissioner's order imposing penalty, emphasizing strict compliance with Registration Certificate specifications for concessional tax eligibility.
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