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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SC dismissed the Special Leave Petition, affirming the High Court's concession on taxation principles. The court emphasized that if the Corporation believed its counsel wrongly conceded a legal point, it should have immediately sought clarification from the High Court. The tribunal condemned the practice of challenging counsel's concessions belatedly, ruling that such post-facto challenges are procedurally inappropriate. The decision underscores the importance of timely legal interventions and the binding nature of counsel's representations before judicial forums.
SC dismissed the Special Leave Petition, affirming the High Court's concession on taxation principles. The court emphasized that if the Corporation believed its counsel wrongly conceded a legal point, it should have immediately sought clarification from the High Court. The tribunal condemned the practice of challenging counsel's concessions belatedly, ruling that such post-facto challenges are procedurally inappropriate. The decision underscores the importance of timely legal interventions and the binding nature of counsel's representations before judicial forums.
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