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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
SC upheld tax exemption benefits granted to respondent under Package Scheme of Incentives 1993, ruling that amended Section 8(5) of CST Act requiring Form 'C' and 'D' for interstate sales applies prospectively from 11.05.2002. Respondent's eligibility certificate dated 20.02.1998 and entitlement certificate dated 24.03.1998 granted absolute exemption up to 2012 or Rs.273.54 crore without Form 'C'/'D' requirements. State's revision notices demanding exempted tax for non-submission of forms were invalidated as substantive rights had accrued prior to amendment. Court emphasized retrospective application would impair vested rights, dismissing appeal and confirming exemptions without form submission requirements for pre-amendment period.
SC upheld tax exemption benefits granted to respondent under Package Scheme of Incentives 1993, ruling that amended Section 8(5) of CST Act requiring Form 'C' and 'D' for interstate sales applies prospectively from 11.05.2002. Respondent's eligibility certificate dated 20.02.1998 and entitlement certificate dated 24.03.1998 granted absolute exemption up to 2012 or Rs.273.54 crore without Form 'C'/'D' requirements. State's revision notices demanding exempted tax for non-submission of forms were invalidated as substantive rights had accrued prior to amendment. Court emphasized retrospective application would impair vested rights, dismissing appeal and confirming exemptions without form submission requirements for pre-amendment period.
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