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 disposed of writ petition seeking to quash seizure panchanamas of gold jewellery worth Rs.3.17 crores weighing 4698.81 grams claimed as stock-in-trade. Gold was initially seized by Railway Police Force and subsequently requisitioned by Deputy Director of Income Tax under Section 132A of IT Act. Petitioner filed application for release under Section 132B to DDIT(Inv.) instead of Assessing Officer as statutorily required. HC directed that application be decided by proper AO within six weeks, finding interest of justice required compliance with first proviso to Section 132B requiring application to AO rather than DDIT(Inv.).
HC disposed of writ petition seeking to quash seizure panchanamas of gold jewellery worth Rs.3.17 crores weighing 4698.81 grams claimed as stock-in-trade. Gold was initially seized by Railway Police Force and subsequently requisitioned by Deputy Director of Income Tax under Section 132A of IT Act. Petitioner filed application for release under Section 132B to DDIT(Inv.) instead of Assessing Officer as statutorily required. HC directed that application be decided by proper AO within six weeks, finding interest of justice required compliance with first proviso to Section 132B requiring application to AO rather than DDIT(Inv.).
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