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...
Ex parte adjudication orders were set aside because the petitioner had not been given an effective opportunity to reply to the show cause notice. The HC accepted that the petitioner could place material before the authority, including the objection that two orders had been passed for the same tax period on the same ITC mismatch ground. The matter was remitted for fresh consideration from the stage of reply to the show cause notice, with all merits contentions left open, subject to payment of 10% of the tax demand under the specified annexures.
Ex parte adjudication orders were set aside because the petitioner had not been given an effective opportunity to reply to the show cause notice. The HC accepted that the petitioner could place material before the authority, including the objection that two orders had been passed for the same tax period on the same ITC mismatch ground. The matter was remitted for fresh consideration from the stage of reply to the show cause notice, with all merits contentions left open, subject to payment of 10% of the tax demand under the specified annexures.
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