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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HC entertained a challenge to a composite demand-cum-show cause notice issued under Section 74 of the CGST Act, 2017 covering multiple tax periods. Observing that a coordinate bench had earlier granted a reasoned interim order in similar matters, and that no contrary view had been taken by any other bench, the HC applied the rule of consistency and noted that three other HCs had decided the issue in favour of assessees. Finding a prima facie case, the HC granted interim protection in the present and connected petitions where no interim relief had yet been granted. Application disposed.
HC entertained a challenge to a composite demand-cum-show cause notice issued under Section 74 of the CGST Act, 2017 covering multiple tax periods. Observing that a coordinate bench had earlier granted a reasoned interim order in similar matters, and that no contrary view had been taken by any other bench, the HC applied the rule of consistency and noted that three other HCs had decided the issue in favour of assessees. Finding a prima facie case, the HC granted interim protection in the present and connected petitions where no interim relief had yet been granted. Application disposed.
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