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 dismisses input tax credit (ITC) claim, holding that the petitioner cannot claim ITC when the supplier failed to deposit mandatory tax under Section 16(2)(c). Despite various precedents cited, the court emphasized the clear statutory requirement of actual tax payment by the supplier to the government. The provision mandates that ITC eligibility is contingent upon the supplier's tax compliance, and in this case, Shree Radhey International neither deposited the tax nor maintained valid registration. The court rejected the petitioner's arguments and upheld the taxing authorities' decision, thereby dismissing the petition without any further interference.
HC dismisses input tax credit (ITC) claim, holding that the petitioner cannot claim ITC when the supplier failed to deposit mandatory tax under Section 16(2)(c). Despite various precedents cited, the court emphasized the clear statutory requirement of actual tax payment by the supplier to the government. The provision mandates that ITC eligibility is contingent upon the supplier's tax compliance, and in this case, Shree Radhey International neither deposited the tax nor maintained valid registration. The court rejected the petitioner's arguments and upheld the taxing authorities' decision, thereby dismissing the petition without any further interference.
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