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 affirmed the Tribunal's factual finding that the product (Byozyme) was correctly characterized for sales-tax purposes in favour of the assessee, holding that the Tribunal's conclusion was supported by admissible evidence, not perverse, and did not result from exclusion of relevant material or misapplication of legal principles. The Court emphasized its limited reference jurisdiction and declined to reappraise evidence merely because an alternative view was possible, finding no error on primary facts or in law warranting interference. Consequently the reference was answered in favour of the assessee and the Revenue's challenge was dismissed; the matter is disposed of.
The HC affirmed the Tribunal's factual finding that the product (Byozyme) was correctly characterized for sales-tax purposes in favour of the assessee, holding that the Tribunal's conclusion was supported by admissible evidence, not perverse, and did not result from exclusion of relevant material or misapplication of legal principles. The Court emphasized its limited reference jurisdiction and declined to reappraise evidence merely because an alternative view was possible, finding no error on primary facts or in law warranting interference. Consequently the reference was answered in favour of the assessee and the Revenue's challenge was dismissed; the matter is disposed of.
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