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 show cause notice challenging GST levy on educational activities was contested; the adjudicatory order issued during pendency of an interim order was set aside, and the matter remitted to the stage of reply to the show cause notice, permitting the petitioner to file a reply. The adjudicating authority is directed to consider the legal position advanced by the petitioner when proceeding further. All substantive contentions on merits have been left open for fresh consideration upon re-adjudication.
Validity of show cause notice challenging GST levy on educational activities was contested; the adjudicatory order issued during pendency of an interim order was set aside, and the matter remitted to the stage of reply to the show cause notice, permitting the petitioner to file a reply. The adjudicating authority is directed to consider the legal position advanced by the petitioner when proceeding further. All substantive contentions on merits have been left open for fresh consideration upon re-adjudication.
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