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 challenge by the dealer-applicant and upheld the authorities' imposition of entry tax under the Entry Tax Act at the rates notified under Section 4A. The court held that the chargeable event is the entry of scheduled goods into the local area and that once goods are identified as used mainly for manufacturing and a Section 4A notification is issued for specified local areas, tax must be levied at the notified rates (6% and 10% for explosives) rather than rates in Section 4. The Tribunal's application of the raw-material definition did not vitiate the chargeability, and, in absence of any challenge to the notification, the references were finally disposed.
The HC dismissed the challenge by the dealer-applicant and upheld the authorities' imposition of entry tax under the Entry Tax Act at the rates notified under Section 4A. The court held that the chargeable event is the entry of scheduled goods into the local area and that once goods are identified as used mainly for manufacturing and a Section 4A notification is issued for specified local areas, tax must be levied at the notified rates (6% and 10% for explosives) rather than rates in Section 4. The Tribunal's application of the raw-material definition did not vitiate the chargeability, and, in absence of any challenge to the notification, the references were finally disposed.
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