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 set aside the respondent's rejection of the petitioner's Form No.1 declaration under the DTVSV Scheme, 2024, holding that mandation to file the appeal online under Rule 45 did not render the manually filed appeal invalid; the appeal is to be treated as pending on the specified cut-off date for eligibility and calculation of disputed tax in terms of the Scheme. The court found the respondent unjustified in denying scheme relief and directed the respondent to process the petitioner's declaration under the DTVSV Scheme, 2024. Parties are anonymized; relief is declaratory and procedural, compelling administrative compliance with the Scheme.
The HC set aside the respondent's rejection of the petitioner's Form No.1 declaration under the DTVSV Scheme, 2024, holding that mandation to file the appeal online under Rule 45 did not render the manually filed appeal invalid; the appeal is to be treated as pending on the specified cut-off date for eligibility and calculation of disputed tax in terms of the Scheme. The court found the respondent unjustified in denying scheme relief and directed the respondent to process the petitioner's declaration under the DTVSV Scheme, 2024. Parties are anonymized; relief is declaratory and procedural, compelling administrative compliance with the Scheme.
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