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 Exhibit-P1 and Exhibit-P2 orders related to ITC disallowance. Relying on the precedent in Rejimon Padickapparambil Alex v. UOI, the court held that electronic credit ledger represents a tax fund with distinct compartments for CGST, IGST, and SGST. The impugned orders were set aside, directing the respondent to reconsider the matter in light of the established legal principles, effectively providing relief to the petitioner by mandating a comprehensive reevaluation of the original tax credit determination.
HC allowed the petition challenging Exhibit-P1 and Exhibit-P2 orders related to ITC disallowance. Relying on the precedent in Rejimon Padickapparambil Alex v. UOI, the court held that electronic credit ledger represents a tax fund with distinct compartments for CGST, IGST, and SGST. The impugned orders were set aside, directing the respondent to reconsider the matter in light of the established legal principles, effectively providing relief to the petitioner by mandating a comprehensive reevaluation of the original tax credit determination.
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