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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In HC, the petition challenging cancellation of the petitioner's GST registration was dismissed insofar as the statutory appeal under Section 107 was rejected solely for delay in filing; the impugned order of cancellation remains operative. For ends of justice, the Court granted the petitioner an equitable opportunity to be heard and directed the departmental authority to issue a fresh show-cause notice to the petitioner by email or registered post, afford a personal hearing, and pass a reasoned order within eight weeks from issuance. The petition was disposed of accordingly, subject to compliance with the Court's directions.
In HC, the petition challenging cancellation of the petitioner's GST registration was dismissed insofar as the statutory appeal under Section 107 was rejected solely for delay in filing; the impugned order of cancellation remains operative. For ends of justice, the Court granted the petitioner an equitable opportunity to be heard and directed the departmental authority to issue a fresh show-cause notice to the petitioner by email or registered post, afford a personal hearing, and pass a reasoned order within eight weeks from issuance. The petition was disposed of accordingly, subject to compliance with the Court's directions.
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