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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
On repeal/omission of CGST Rules 89(4B) and 96(10) by Notification dated 08 October 2024, and in the absence of any saving clause or applicability of Section 6 of the General Clauses Act, pending proceedings founded on the omitted provisions are not preserved; undisposed show cause notices, and orders (whether passed after 08 October 2024 or passed earlier but not yet final due to appeal/challenge and not "transactions past and closed") stand lapsed, leading to disposal of the petition. The revenue was left at liberty to initiate action on any other issue, with all contentions, including competence, kept open. - HC
On repeal/omission of CGST Rules 89(4B) and 96(10) by Notification dated 08 October 2024, and in the absence of any saving clause or applicability of Section 6 of the General Clauses Act, pending proceedings founded on the omitted provisions are not preserved; undisposed show cause notices, and orders (whether passed after 08 October 2024 or passed earlier but not yet final due to appeal/challenge and not "transactions past and closed") stand lapsed, leading to disposal of the petition. The revenue was left at liberty to initiate action on any other issue, with all contentions, including competence, kept open. - HC
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