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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Eligibility for Input Tax Credit was reconsidered in light of retrospective insertion of provisions into the GST enactments, the legal basis being the Finance (No.2) Act, 2024 rendering the issue subject to fresh merits scrutiny; consequence: assessment quashed and matter remitted for re-examination of entitlement to ITC notwithstanding belated availment. The prospect of waiver of interest and penalty under the relevant statutory provision was noted as a collateral relief subject to reconsideration. Writ jurisdiction was exercised to set aside the impugned assessment and direct expeditious fresh decision on merits by the assessing authority.
Eligibility for Input Tax Credit was reconsidered in light of retrospective insertion of provisions into the GST enactments, the legal basis being the Finance (No.2) Act, 2024 rendering the issue subject to fresh merits scrutiny; consequence: assessment quashed and matter remitted for re-examination of entitlement to ITC notwithstanding belated availment. The prospect of waiver of interest and penalty under the relevant statutory provision was noted as a collateral relief subject to reconsideration. Writ jurisdiction was exercised to set aside the impugned assessment and direct expeditious fresh decision on merits by the assessing authority.
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