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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Portal-based GST appeal compliance required the appellate authority to examine whether an earlier deposit could be adjusted as the pre-deposit for appeals against de novo assessment orders. The High Court directed consideration of the taxpayer's representation in light of the GST portal appeal manual, including the need for approval from the competent authority, and with reference to the Supreme Court ruling in VVF (India) Limited. The writ petitions were disposed of with a direction to decide the request for recognition of the amount already deposited for appeal purposes.
Portal-based GST appeal compliance required the appellate authority to examine whether an earlier deposit could be adjusted as the pre-deposit for appeals against de novo assessment orders. The High Court directed consideration of the taxpayer's representation in light of the GST portal appeal manual, including the need for approval from the competent authority, and with reference to the Supreme Court ruling in VVF (India) Limited. The writ petitions were disposed of with a direction to decide the request for recognition of the amount already deposited for appeal purposes.
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