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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
A High Court refused to quash a prosecution for failure to pay admitted tax and interest liability, noting that the return had been filed but the amount remained unpaid within the stipulated or extended period and a later demand also stayed outstanding. It also observed that no effective challenge to the assessment had been pursued for years, and that a delayed appeal had not been admitted or the delay condoned. As the trial had already reached the final stage and the same grounds had been raised before the trial court, the Court held that the quash petition was belated and not maintainable. The criminal case was left to be decided on its own merits.
A High Court refused to quash a prosecution for failure to pay admitted tax and interest liability, noting that the return had been filed but the amount remained unpaid within the stipulated or extended period and a later demand also stayed outstanding. It also observed that no effective challenge to the assessment had been pursued for years, and that a delayed appeal had not been admitted or the delay condoned. As the trial had already reached the final stage and the same grounds had been raised before the trial court, the Court held that the quash petition was belated and not maintainable. The criminal case was left to be decided on its own merits.
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