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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Profiteering under the GST framework was found arising from failure to pass on input tax credit; the investigative report's computations were accepted as conclusive and used to quantify profiteering and a proportional adjustment for completed work, resulting in a specified amount payable to the applicant. The respondent is directed to pay the proportionate profiteered amount to the applicant with interest calculated under the CGST Rules and to submit a compliance report to tax authorities within the prescribed timeframe.
Profiteering under the GST framework was found arising from failure to pass on input tax credit; the investigative report's computations were accepted as conclusive and used to quantify profiteering and a proportional adjustment for completed work, resulting in a specified amount payable to the applicant. The respondent is directed to pay the proportionate profiteered amount to the applicant with interest calculated under the CGST Rules and to submit a compliance report to tax authorities within the prescribed timeframe.
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