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 dismissed Revenue's appeal regarding TCS collection responsibility under s.206C. Court held that verification requirements in Form 27C apply solely to purchasers as declarants, not sellers. Revenue's contention that sellers must verify declarations was found contrary to s.206C(1A) read with Rule 37C. The Court emphasized that neither the Act nor Rules impose verification duties on sellers. Following precedent from A.A. Estate, HC determined no substantial question of law existed warranting admission under s.260-A, as Revenue's interpretation contradicted clear statutory provisions regarding TCS collection and declaration procedures.
HC dismissed Revenue's appeal regarding TCS collection responsibility under s.206C. Court held that verification requirements in Form 27C apply solely to purchasers as declarants, not sellers. Revenue's contention that sellers must verify declarations was found contrary to s.206C(1A) read with Rule 37C. The Court emphasized that neither the Act nor Rules impose verification duties on sellers. Following precedent from A.A. Estate, HC determined no substantial question of law existed warranting admission under s.260-A, as Revenue's interpretation contradicted clear statutory provisions regarding TCS collection and declaration procedures.
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