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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Rectification of GST records was challenged on grounds that an application seeking correction and reconciliation of input tax credit (ITC) was rejected without affording an opportunity of hearing and without verifying uploaded portal records. The court found the rejection procedurally defective for not recording reasons for disregarding submitted reconciliation statements and supporting documents, and for failing to provide a personal hearing; therefore the rejection order was set aside. The matter is remanded for fresh disposal of the rectification application, with directions to consider portal evidence, allow the applicant to present documents and explanations, and hear the applicant within a specified short period.
Rectification of GST records was challenged on grounds that an application seeking correction and reconciliation of input tax credit (ITC) was rejected without affording an opportunity of hearing and without verifying uploaded portal records. The court found the rejection procedurally defective for not recording reasons for disregarding submitted reconciliation statements and supporting documents, and for failing to provide a personal hearing; therefore the rejection order was set aside. The matter is remanded for fresh disposal of the rectification application, with directions to consider portal evidence, allow the applicant to present documents and explanations, and hear the applicant within a specified short period.
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