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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The dominant issue was whether an appeal against cancellation of GST registration, filed long after the statutory period, should be entertained despite the assessee's failure to respond to the SCN and to furnish returns under Section 39 of the CGST Act. Relying on its interim approach extending time for filing GST appeals and noting that the assessee's contentions had not been examined on merits even by the adjudicating authority, the Court directed that the appeal be heard on merits, subject to payment of costs of Rs. 25,000 and compliance with filing requirements by the stipulated date, and restored the appeal before the appellate authority. - HC
The dominant issue was whether an appeal against cancellation of GST registration, filed long after the statutory period, should be entertained despite the assessee's failure to respond to the SCN and to furnish returns under Section 39 of the CGST Act. Relying on its interim approach extending time for filing GST appeals and noting that the assessee's contentions had not been examined on merits even by the adjudicating authority, the Court directed that the appeal be heard on merits, subject to payment of costs of Rs. 25,000 and compliance with filing requirements by the stipulated date, and restored the appeal before the appellate authority. - HC
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