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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Assessment relating to alleged excess/irregular ITC availment and consequential interest and late-fee liabilities was interfered with on the ground that the matter required reconsideration on merits after a proper reply and supporting documents. The impugned order was directed to be treated as an addendum to the show-cause notice, and the authority was mandated to pass a fresh final order in accordance with law after considering the taxpayer's reply. The remand was made conditional upon deposit of 50% of the disputed tax (in cash through the electronic cash ledger) within 30 days; upon such compliance, the bank-account attachment was to stand automatically vacated and the authority to decide expeditiously. - HC
Assessment relating to alleged excess/irregular ITC availment and consequential interest and late-fee liabilities was interfered with on the ground that the matter required reconsideration on merits after a proper reply and supporting documents. The impugned order was directed to be treated as an addendum to the show-cause notice, and the authority was mandated to pass a fresh final order in accordance with law after considering the taxpayer's reply. The remand was made conditional upon deposit of 50% of the disputed tax (in cash through the electronic cash ledger) within 30 days; upon such compliance, the bank-account attachment was to stand automatically vacated and the authority to decide expeditiously. - HC
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