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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A writ petition challenging the order confirming the proposal in the show cause notice was disposed of by directing a de novo adjudication on merits, subject to the petitioner's compliance with an additional pre-deposit condition. The Court accepted the petitioner's willingness to deposit an extra 15% of the disputed tax over and above the amount already pre-deposited at appeal stage, and required a reply to the show cause notice with supporting documents. The impugned order was treated as an addendum to the notice, earlier payments were to be adjusted subject to verification, and lifting of the bank attachment was made conditional on compliance and the absence of other arrears.
A writ petition challenging the order confirming the proposal in the show cause notice was disposed of by directing a de novo adjudication on merits, subject to the petitioner's compliance with an additional pre-deposit condition. The Court accepted the petitioner's willingness to deposit an extra 15% of the disputed tax over and above the amount already pre-deposited at appeal stage, and required a reply to the show cause notice with supporting documents. The impugned order was treated as an addendum to the notice, earlier payments were to be adjusted subject to verification, and lifting of the bank attachment was made conditional on compliance and the absence of other arrears.
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