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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Registration suspended at the time of supply prevents a post suspension tax invoice from substituting for prescribed transit documentation; because the supplier's registration remained suspended and no e way bill or other specified documents accompanied the goods, the tax invoice could not be treated as the required document under the statutory scheme. The administrative circular relied upon is inapplicable where prescribed documents are absent. Consequence: petitions challenging seizure and related orders were dismissed for lack of compliance with the e way bill and specified document requirements.
Registration suspended at the time of supply prevents a post suspension tax invoice from substituting for prescribed transit documentation; because the supplier's registration remained suspended and no e way bill or other specified documents accompanied the goods, the tax invoice could not be treated as the required document under the statutory scheme. The administrative circular relied upon is inapplicable where prescribed documents are absent. Consequence: petitions challenging seizure and related orders were dismissed for lack of compliance with the e way bill and specified document requirements.
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