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 granted partial relief to state-owned corporation, staying impugned tax order contingent on depositing Rs. 30 crore within three weeks. The court considered the corporation's critical role in executing state welfare schemes and managing pension funds. While rejecting full stay of the 20% tax demand (approximately Rs. 126 crore), the court allowed the petitioner to challenge the order before the Appellate Authority, balancing fiscal obligations with the corporation's public service mandate. The conditional stay provides temporary reprieve while preserving the respondents' right to pursue tax recovery.
HC granted partial relief to state-owned corporation, staying impugned tax order contingent on depositing Rs. 30 crore within three weeks. The court considered the corporation's critical role in executing state welfare schemes and managing pension funds. While rejecting full stay of the 20% tax demand (approximately Rs. 126 crore), the court allowed the petitioner to challenge the order before the Appellate Authority, balancing fiscal obligations with the corporation's public service mandate. The conditional stay provides temporary reprieve while preserving the respondents' right to pursue tax recovery.
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