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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Issue was whether GST exemption under Notification No. 16/2025-Central Tax (Rate) applied to a group health insurance policy covering a large body of members. The court held that IRDAI (Health Insurance) Regulations, 2016 prohibit forming a group solely to obtain insurance and require an identifiable relationship between members and the group policyholder; issuance of the policy by a regulated insurer and the tendering/collective bargaining process established such relationship and a common welfare purpose. Accordingly, the notification was construed as exempting only individual health insurance policies, not group policies negotiated through collective arrangements, and the writ petitions were dismissed. - HC
Issue was whether GST exemption under Notification No. 16/2025-Central Tax (Rate) applied to a group health insurance policy covering a large body of members. The court held that IRDAI (Health Insurance) Regulations, 2016 prohibit forming a group solely to obtain insurance and require an identifiable relationship between members and the group policyholder; issuance of the policy by a regulated insurer and the tendering/collective bargaining process established such relationship and a common welfare purpose. Accordingly, the notification was construed as exempting only individual health insurance policies, not group policies negotiated through collective arrangements, and the writ petitions were dismissed. - HC
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