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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The HC allowed the petition challenging the ASJ's orders requiring deposit of 20% compensation under Section 148 of the NI Act. The Court found that the ASJ's reasoning was insufficient, as neither the NI Act's presumptions nor the petitioner's conviction by the MM constituted adequate grounds for mandating the deposit at the appeal's threshold. The Court determined that requiring such deposit would effectively prejudge the pending appeal. The HC concluded that the ASJ failed to provide clear findings regarding whether the petitioner had established exceptional circumstances warranting waiver of the deposit requirement, rendering the impugned orders inadequate in their reasoning and justification.
The HC allowed the petition challenging the ASJ's orders requiring deposit of 20% compensation under Section 148 of the NI Act. The Court found that the ASJ's reasoning was insufficient, as neither the NI Act's presumptions nor the petitioner's conviction by the MM constituted adequate grounds for mandating the deposit at the appeal's threshold. The Court determined that requiring such deposit would effectively prejudge the pending appeal. The HC concluded that the ASJ failed to provide clear findings regarding whether the petitioner had established exceptional circumstances warranting waiver of the deposit requirement, rendering the impugned orders inadequate in their reasoning and justification.
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