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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Profiteering in sale of residential units and obligation to pass on input tax credit under Section 171 is examined, with area-based computation adopted and rejection of an ITC-to-turnover ratio. The investigation under Rule 129 and DGAP report quantified a profiteered amount of Rs. 40,096, requiring refund and proportionate distribution to 1,865 eligible buyers; the respondent accepted the report and agreed to comply. Interest on the profiteered amount under Rule 133(3)(b) and filing of a compliance report to DGAP and the jurisdictional GST Commissioner are directed as operative consequences.
Profiteering in sale of residential units and obligation to pass on input tax credit under Section 171 is examined, with area-based computation adopted and rejection of an ITC-to-turnover ratio. The investigation under Rule 129 and DGAP report quantified a profiteered amount of Rs. 40,096, requiring refund and proportionate distribution to 1,865 eligible buyers; the respondent accepted the report and agreed to comply. Interest on the profiteered amount under Rule 133(3)(b) and filing of a compliance report to DGAP and the jurisdictional GST Commissioner are directed as operative consequences.
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