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 allowed the petition challenging license denial, distinguishing between "contravention" and "offence" under indirect tax laws. The court found pending litigation does not automatically constitute an offence under para 3(2)(c) of the Regulation. No actual penalties were imposed against the petitioner's company or its officers. The impugned orders were quashed, directing respondents to issue the license within two weeks upon fulfilling other regulatory conditions, effectively rejecting the administrative denial based on pending legal proceedings.
HC allowed the petition challenging license denial, distinguishing between "contravention" and "offence" under indirect tax laws. The court found pending litigation does not automatically constitute an offence under para 3(2)(c) of the Regulation. No actual penalties were imposed against the petitioner's company or its officers. The impugned orders were quashed, directing respondents to issue the license within two weeks upon fulfilling other regulatory conditions, effectively rejecting the administrative denial based on pending legal proceedings.
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