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 AT dismissed the appeal and upheld the provisional attachment order. The tribunal found the impugned order was not mechanically passed and that the appellant's contention-predicated on declined prosecution sanction against certain officials and characterization of the dispute as purely contractual-failed. Evidence did not support short supply of the contracted brand or any prior consent to substitute other branded PDW; moreover, claims for payment for the contracted brand contradicted the appellant's contractual-dispute plea. The AT concluded the facts disclosed not only breach of contract but also an intent to deceive by supplying unapproved brands without competent authority permission, thereby justifying continuation of criminal proceedings and maintenance of the attachment.
The AT dismissed the appeal and upheld the provisional attachment order. The tribunal found the impugned order was not mechanically passed and that the appellant's contention-predicated on declined prosecution sanction against certain officials and characterization of the dispute as purely contractual-failed. Evidence did not support short supply of the contracted brand or any prior consent to substitute other branded PDW; moreover, claims for payment for the contracted brand contradicted the appellant's contractual-dispute plea. The AT concluded the facts disclosed not only breach of contract but also an intent to deceive by supplying unapproved brands without competent authority permission, thereby justifying continuation of criminal proceedings and maintenance of the attachment.
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