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 petition challenging gold seizure under GST Act. Petitioner conducted unregistered sales of old gold worth Rs.47.73 Crores, with transactions lacking proper tax documentation. Time extension for investigation granted under Section 67 proviso nullified petitioner's limitation argument. Court found confiscation proceedings under Section 130 prima facie valid, directing petitioner to participate in proceedings. Petitioner retains right to seek provisional release of seized gold under Section 130(2) during confiscation proceedings. Investigation revealed unauthorized procurement and supply between entities without mandatory GST documentation. Dismissal upholds administrative authority's jurisdiction while preserving statutory remedies available to petitioner.
HC dismissed petition challenging gold seizure under GST Act. Petitioner conducted unregistered sales of old gold worth Rs.47.73 Crores, with transactions lacking proper tax documentation. Time extension for investigation granted under Section 67 proviso nullified petitioner's limitation argument. Court found confiscation proceedings under Section 130 prima facie valid, directing petitioner to participate in proceedings. Petitioner retains right to seek provisional release of seized gold under Section 130(2) during confiscation proceedings. Investigation revealed unauthorized procurement and supply between entities without mandatory GST documentation. Dismissal upholds administrative authority's jurisdiction while preserving statutory remedies available to petitioner.
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