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 found prima facie merit in the petitioner's challenge to the respondent's inaction on revalidation of import licences but declined to grant pre-emptory relief or issue a writ of mandamus directing revalidation. Instead, the HC directed the respondent's PRC to reconsider the petitioner's revalidation requests in light of all relevant facts, including decisions concerning similarly situated importers, and to render a reasoned decision. The PRC was instructed to complete the fresh examination expeditiously and preferably within six weeks. The petition was disposed of accordingly.
The HC found prima facie merit in the petitioner's challenge to the respondent's inaction on revalidation of import licences but declined to grant pre-emptory relief or issue a writ of mandamus directing revalidation. Instead, the HC directed the respondent's PRC to reconsider the petitioner's revalidation requests in light of all relevant facts, including decisions concerning similarly situated importers, and to render a reasoned decision. The PRC was instructed to complete the fresh examination expeditiously and preferably within six weeks. The petition was disposed of accordingly.
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