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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GST proceedings on seigniorage fee/royalty for quarrying and transporting minerals were not finally adjudicated on merits because the levy issue is pending before the Supreme Court. The High Court found the facts to be almost identical to an earlier case and disposed of the writ petitions on the same terms, directing that the impugned proceedings remain in abeyance and that the respondent proceed in accordance with law after the Supreme Court decision. The Court therefore declined to examine the substantive GST demand at this stage and applied the earlier identical order.
GST proceedings on seigniorage fee/royalty for quarrying and transporting minerals were not finally adjudicated on merits because the levy issue is pending before the Supreme Court. The High Court found the facts to be almost identical to an earlier case and disposed of the writ petitions on the same terms, directing that the impugned proceedings remain in abeyance and that the respondent proceed in accordance with law after the Supreme Court decision. The Court therefore declined to examine the substantive GST demand at this stage and applied the earlier identical order.
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