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 upheld the imposition of INR 50,000/- costs against DRI officials, finding the procedural delays arose from complex legal and jurisdictional uncertainties rather than administrative negligence. While recognizing the Department's procedural lapses, the court viewed the costs as a measured judicial response to institutional accountability. The court specifically set aside directions mandating cost recovery from individual officers, partially allowing the petition and maintaining the principle of institutional responsibility without penalizing specific personnel.
HC upheld the imposition of INR 50,000/- costs against DRI officials, finding the procedural delays arose from complex legal and jurisdictional uncertainties rather than administrative negligence. While recognizing the Department's procedural lapses, the court viewed the costs as a measured judicial response to institutional accountability. The court specifically set aside directions mandating cost recovery from individual officers, partially allowing the petition and maintaining the principle of institutional responsibility without penalizing specific personnel.
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