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 of input tax credit focused on alleged transcription errors in the annual return and failure to produce requisite e-way bills; the petitioner must produce all e-way bills and transport documents to substantiate movement of goods, failing which sample documents are inadmissible. The respondent is directed to undertake de novo adjudication on remand after affording personal hearing; the petitioner must file detailed submissions within thirty days. If the petitioner does not comply, the respondent may proceed to recover tax as if the writs were dismissed, and the writ petitions are disposed.
Assessment of input tax credit focused on alleged transcription errors in the annual return and failure to produce requisite e-way bills; the petitioner must produce all e-way bills and transport documents to substantiate movement of goods, failing which sample documents are inadmissible. The respondent is directed to undertake de novo adjudication on remand after affording personal hearing; the petitioner must file detailed submissions within thirty days. If the petitioner does not comply, the respondent may proceed to recover tax as if the writs were dismissed, and the writ petitions are disposed.
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