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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The HC dismissed the writ petition challenging the attachment order and bank attachment notice, holding that the petitioner had an alternative efficacious remedy by way of appeal against the assessment order before the appellate authority. The Court declined to entertain the writ petition, emphasizing the availability of the statutory appellate remedy. The petitioner was granted liberty to file the appeal within four weeks from receipt of the order, subject to depositing 25% of the disputed tax (comprising 15% in addition to the statutory 10% deposit). The appellate authority was directed to admit the appeal without insisting on limitation and to adjudicate the matter on merits expeditiously and in accordance with law upon compliance with the deposit condition.
The HC dismissed the writ petition challenging the attachment order and bank attachment notice, holding that the petitioner had an alternative efficacious remedy by way of appeal against the assessment order before the appellate authority. The Court declined to entertain the writ petition, emphasizing the availability of the statutory appellate remedy. The petitioner was granted liberty to file the appeal within four weeks from receipt of the order, subject to depositing 25% of the disputed tax (comprising 15% in addition to the statutory 10% deposit). The appellate authority was directed to admit the appeal without insisting on limitation and to adjudicate the matter on merits expeditiously and in accordance with law upon compliance with the deposit condition.
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