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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The AT accepted the Senior Standing Counsel's legal opinion and held that claims/benefits unquantified due to non-submission of documents by the pre-resolution entity stand extinguished, and the resolution applicant cannot be held liable for the pre-approval failure to pass input tax credit under s.171 CGST Act. Finding no reasonable cause to proceed, the AT closed the s.171 proceedings, set aside the DGAP notice and discharged the resolution applicant from accountability for the predecessor's omission to transfer ITC benefits post-approval of the resolution plan. The Pr. DG's queries and the opinion relied upon were treated as determinative, resulting in final cessation of the contested recovery action.
The AT accepted the Senior Standing Counsel's legal opinion and held that claims/benefits unquantified due to non-submission of documents by the pre-resolution entity stand extinguished, and the resolution applicant cannot be held liable for the pre-approval failure to pass input tax credit under s.171 CGST Act. Finding no reasonable cause to proceed, the AT closed the s.171 proceedings, set aside the DGAP notice and discharged the resolution applicant from accountability for the predecessor's omission to transfer ITC benefits post-approval of the resolution plan. The Pr. DG's queries and the opinion relied upon were treated as determinative, resulting in final cessation of the contested recovery action.
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