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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Challenge concerned legality of demand arising from debonding of capital goods and admissibility of input tax credit (ITC). Court noted customs NOC confirmed IGST liability on debonding of indigenous goods and that payment had been discharged; petitioner contended this precluded a second demand by state authorities, with consequence that the impugned demand for the same IGST was contested. Court recorded petitioners concession not to contest a specified portion relating to tax, interest and penalty, while permitting challenge to remaining demands alleging excess or ineligible ITC; consequence: petitioner directed to pursue remedy before the Joint Commissioner (Appeals) and writ disposed on those terms.
Challenge concerned legality of demand arising from debonding of capital goods and admissibility of input tax credit (ITC). Court noted customs NOC confirmed IGST liability on debonding of indigenous goods and that payment had been discharged; petitioner contended this precluded a second demand by state authorities, with consequence that the impugned demand for the same IGST was contested. Court recorded petitioners concession not to contest a specified portion relating to tax, interest and penalty, while permitting challenge to remaining demands alleging excess or ineligible ITC; consequence: petitioner directed to pursue remedy before the Joint Commissioner (Appeals) and writ disposed on those terms.
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