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 determined that the petitioner's declaration under SABKA VISHWAS (Legacy Dispute Resolution) Scheme, 2019 was invalid. The court found the declaration under "arrears category" contradictory, as the petitioner deliberately misled the system by filing incorrect tax details. The declaration was effectively a "voluntary disclosure" and thus not entitled to scheme benefits. The discharge certificate was deemed non-conclusive, allowing tax authorities to proceed with recovery actions. The court rejected the petitioner's claims, emphasizing the importance of accurate tax reporting and adherence to scheme guidelines, ultimately dismissing the petition.
HC determined that the petitioner's declaration under SABKA VISHWAS (Legacy Dispute Resolution) Scheme, 2019 was invalid. The court found the declaration under "arrears category" contradictory, as the petitioner deliberately misled the system by filing incorrect tax details. The declaration was effectively a "voluntary disclosure" and thus not entitled to scheme benefits. The discharge certificate was deemed non-conclusive, allowing tax authorities to proceed with recovery actions. The court rejected the petitioner's claims, emphasizing the importance of accurate tax reporting and adherence to scheme guidelines, ultimately dismissing the petition.
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