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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Validity of refund sanction orders was examined with primary focus on procedural fairness and the requirement of a reasoned, speaking order. The court found the impugned administrative order failed to consider petitioner's submissions and lacked discussion showing the refund claim was legally incorrect; rejection rested on the department's inability to distinguish payment purpose without contrary material. Consequently the impugned order was held unsustainable for want of a reasoned decision and natural justice, and the matter was directed to be reconsidered or dealt with further to meet the ends of justice.
Validity of refund sanction orders was examined with primary focus on procedural fairness and the requirement of a reasoned, speaking order. The court found the impugned administrative order failed to consider petitioner's submissions and lacked discussion showing the refund claim was legally incorrect; rejection rested on the department's inability to distinguish payment purpose without contrary material. Consequently the impugned order was held unsustainable for want of a reasoned decision and natural justice, and the matter was directed to be reconsidered or dealt with further to meet the ends of justice.
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