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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HC addressed ex parte GST assessment founded on misattribution of turnover due to identical names and reliance on WAMIS/Income-Tax portal data; court accepted concession that assessment targeted an unregistered person mistaken for a registered taxpayer, holding that the assessment under the GST Act and subsequent appellate confirmation were unsustainable. Consequently the impugned assessment order and the appellate order were quashed and set aside and the writ petition was allowed, with pending interlocutory applications disposed of.
HC addressed ex parte GST assessment founded on misattribution of turnover due to identical names and reliance on WAMIS/Income-Tax portal data; court accepted concession that assessment targeted an unregistered person mistaken for a registered taxpayer, holding that the assessment under the GST Act and subsequent appellate confirmation were unsustainable. Consequently the impugned assessment order and the appellate order were quashed and set aside and the writ petition was allowed, with pending interlocutory applications disposed of.
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