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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Writ jurisdiction was declined because an efficacious statutory appeal lay before the GST Appellate Tribunal, including on the question of limitation before the first appellate authority. The petition was also procedurally deficient as the petitioner failed to place the revocation-rejection order on record, preventing proper scrutiny. In view of the available alternate remedy and the incomplete record, the court dismissed the petition, while granting liberty to pursue the remedy available in law.
Writ jurisdiction was declined because an efficacious statutory appeal lay before the GST Appellate Tribunal, including on the question of limitation before the first appellate authority. The petition was also procedurally deficient as the petitioner failed to place the revocation-rejection order on record, preventing proper scrutiny. In view of the available alternate remedy and the incomplete record, the court dismissed the petition, while granting liberty to pursue the remedy available in law.
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