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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An assessment under Section 73 of the Tamil Nadu GST Act was set aside because the assessing authority did not adequately consider the assessee's documentary evidence on mismatch, alleged hypothetical supplies and double taxation. The court noted that the dispute depended on verification and reconciliation of the supporting material already stated to have been filed, so the proper course was to allow the assessee to file an additional reply and documents item-wise before the original authority. The matter was remanded for fresh consideration and correct determination of liability after granting that opportunity.
An assessment under Section 73 of the Tamil Nadu GST Act was set aside because the assessing authority did not adequately consider the assessee's documentary evidence on mismatch, alleged hypothetical supplies and double taxation. The court noted that the dispute depended on verification and reconciliation of the supporting material already stated to have been filed, so the proper course was to allow the assessee to file an additional reply and documents item-wise before the original authority. The matter was remanded for fresh consideration and correct determination of liability after granting that opportunity.
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