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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Allegations concern whether a supplier passed the benefit of input tax credit to purchasers by reducing prices; this requires verification of documentary evidence and calculation of the claimed Rs.173 per buyer and alleged Rs.32.78 per sq ft profiteering. Limitation objections under sections governing recovery of tax were raised by the respondent and must be examined against the investigative record. The Appellate Tribunal directed re investigation by the DGAP under the procedural rule for further factual and accounting scrutiny to determine if a commensurate price reduction was effected and whether statutory time limit defenses bar recovery.
Allegations concern whether a supplier passed the benefit of input tax credit to purchasers by reducing prices; this requires verification of documentary evidence and calculation of the claimed Rs.173 per buyer and alleged Rs.32.78 per sq ft profiteering. Limitation objections under sections governing recovery of tax were raised by the respondent and must be examined against the investigative record. The Appellate Tribunal directed re investigation by the DGAP under the procedural rule for further factual and accounting scrutiny to determine if a commensurate price reduction was effected and whether statutory time limit defenses bar recovery.
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