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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Provisional attachment of bank accounts under GST can be relaxed where substitute security adequately protects revenue. The High Court accepted the petitioner's fixed deposit as sufficient security, permitted operation of the attached accounts, and quashed the attachment only to that extent. The investigation, scrutiny of invoices and other material, and any future show cause notice were left unaffected. The deposit was directed to remain available for adjustment against any liability finally determined, and to be returned with accrued interest if the final adjudication favoured the petitioner.
Provisional attachment of bank accounts under GST can be relaxed where substitute security adequately protects revenue. The High Court accepted the petitioner's fixed deposit as sufficient security, permitted operation of the attached accounts, and quashed the attachment only to that extent. The investigation, scrutiny of invoices and other material, and any future show cause notice were left unaffected. The deposit was directed to remain available for adjustment against any liability finally determined, and to be returned with accrued interest if the final adjudication favoured the petitioner.
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