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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Proceedings under Section 129 of the CGST Act were initiated solely because the e-way bill reflected an incorrect PIN code for the "ship to" location, though the consignee details and destination (Samastipur, Bihar) were otherwise correctly stated and the goods were accompanied by requisite documents including tax invoice, e-way bill and GR. Applying the legal position that a mere PIN code error, when the consignor/consignee address is otherwise correct, does not justify detention proceedings under Section 129, the impugned detention and penalty orders were held unsustainable and were quashed, and the writ petition was allowed. - HC
Proceedings under Section 129 of the CGST Act were initiated solely because the e-way bill reflected an incorrect PIN code for the "ship to" location, though the consignee details and destination (Samastipur, Bihar) were otherwise correctly stated and the goods were accompanied by requisite documents including tax invoice, e-way bill and GR. Applying the legal position that a mere PIN code error, when the consignor/consignee address is otherwise correct, does not justify detention proceedings under Section 129, the impugned detention and penalty orders were held unsustainable and were quashed, and the writ petition was allowed. - HC
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