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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Summons issued under Section 70 of the CGST Act are a statutory tool for inquiry to secure attendance, evidence, and production of documents, and such inquiry is deemed a judicial proceeding under Section 70(2) read with Sections 193 and 228 of the IPC. Since a summons under Section 70 is primarily for information-gathering and affording an opportunity to produce material, it does not amount to initiation of proceedings against the noticee, and objections alleging violation of internal guidelines do not justify quashing at this stage. Consequently, the writ petitions challenging the summons were held to be premature and were dismissed. - HC
Summons issued under Section 70 of the CGST Act are a statutory tool for inquiry to secure attendance, evidence, and production of documents, and such inquiry is deemed a judicial proceeding under Section 70(2) read with Sections 193 and 228 of the IPC. Since a summons under Section 70 is primarily for information-gathering and affording an opportunity to produce material, it does not amount to initiation of proceedings against the noticee, and objections alleging violation of internal guidelines do not justify quashing at this stage. Consequently, the writ petitions challenging the summons were held to be premature and were dismissed. - HC
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