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 adjudicated a tax dispute regarding cash payments exceeding Rs.20,000 for milk procurement. The court interpreted Rule 6DD restrictively, holding that the term 'producer' specifically refers to dairy farmers, not companies engaged in milk pasteurization. The court emphasized the legislative intent of Section 40A(3) to discourage cash transactions, noting both transacting entities had banking facilities. The court rejected the appellant's argument that pasteurization constitutes production, thereby disallowing cash payment deductions. The ruling prioritized the statutory objective of promoting banking transactions and narrowly construed exemption provisions. Decided in favor of revenue, the judgment reinforced strict compliance with cash payment restrictions.
HC adjudicated a tax dispute regarding cash payments exceeding Rs.20,000 for milk procurement. The court interpreted Rule 6DD restrictively, holding that the term 'producer' specifically refers to dairy farmers, not companies engaged in milk pasteurization. The court emphasized the legislative intent of Section 40A(3) to discourage cash transactions, noting both transacting entities had banking facilities. The court rejected the appellant's argument that pasteurization constitutes production, thereby disallowing cash payment deductions. The ruling prioritized the statutory objective of promoting banking transactions and narrowly construed exemption provisions. Decided in favor of revenue, the judgment reinforced strict compliance with cash payment restrictions.
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