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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Vivad Se Vishwas Scheme interpretation clarified that 'dispute' must be read broadly to include any pending appeal, including appeals against penalty orders, thereby bringing such appeals within scheme eligibility; this interpretation advances the scheme's beneficial object and requires departmental consistency where spousal apportionment of income under applicable matrimonial law is governed similarly, resulting in entitlement to settlement where co-claimant spouse obtained benefit; delays due to COVID and filings made while the scheme subsisted do not defeat eligibility, and exercise of writ jurisdiction is appropriate to secure scheme relief in such circumstances.
Vivad Se Vishwas Scheme interpretation clarified that 'dispute' must be read broadly to include any pending appeal, including appeals against penalty orders, thereby bringing such appeals within scheme eligibility; this interpretation advances the scheme's beneficial object and requires departmental consistency where spousal apportionment of income under applicable matrimonial law is governed similarly, resulting in entitlement to settlement where co-claimant spouse obtained benefit; delays due to COVID and filings made while the scheme subsisted do not defeat eligibility, and exercise of writ jurisdiction is appropriate to secure scheme relief in such circumstances.
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