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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Provisional attachment of a bank account under GST was discussed in the context of alleged incorrect reporting of tax liability and excess input tax credit in GSTR-9. The Court noted that the petitioner had neither filed a reply to the show cause notice nor been granted a personal hearing, and treated the right to be heard as part of natural justice. Relief was balanced by requiring deposit of the entire demand before setting aside the adjudication order and allowing fresh reply and hearing. The consequential recovery measures and bank attachment were directed to be lifted, with merits left open for de novo adjudication.
Provisional attachment of a bank account under GST was discussed in the context of alleged incorrect reporting of tax liability and excess input tax credit in GSTR-9. The Court noted that the petitioner had neither filed a reply to the show cause notice nor been granted a personal hearing, and treated the right to be heard as part of natural justice. Relief was balanced by requiring deposit of the entire demand before setting aside the adjudication order and allowing fresh reply and hearing. The consequential recovery measures and bank attachment were directed to be lifted, with merits left open for de novo adjudication.
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