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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Section 6(2)(b) bars parallel adjudicatory proceedings on the same subject matter, but summons and other investigative steps do not by themselves amount to initiation of such proceedings. Applying the Supreme Court's ruling in Armour Security, the HC noted possible overlap between Central and State GST action, but declined to decide the merits of that overlap on the material before it. It directed the assessee to comply with the summons and raise the objection before the concerned authority, while requiring the State and Central authorities to communicate and coordinate so that the assessee is not subjected to multiple adjudicatory processes on the same subject matter. The merits and validity of the summons and notice were left open.
Section 6(2)(b) bars parallel adjudicatory proceedings on the same subject matter, but summons and other investigative steps do not by themselves amount to initiation of such proceedings. Applying the Supreme Court's ruling in Armour Security, the HC noted possible overlap between Central and State GST action, but declined to decide the merits of that overlap on the material before it. It directed the assessee to comply with the summons and raise the objection before the concerned authority, while requiring the State and Central authorities to communicate and coordinate so that the assessee is not subjected to multiple adjudicatory processes on the same subject matter. The merits and validity of the summons and notice were left open.
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