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...
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Writ jurisdiction challenging GST registration cancellation is ordinarily unavailable where the taxpayer failed to pursue the statutory appeal within the prescribed limitation period and shows no exceptional circumstances. A delayed writ petition should not be entertained merely because the appellate remedy has lapsed. The petition was dismissed on that basis, while preserving the taxpayer's ability to file the final return and seek fresh GST registration in accordance with law.
Writ jurisdiction challenging GST registration cancellation is ordinarily unavailable where the taxpayer failed to pursue the statutory appeal within the prescribed limitation period and shows no exceptional circumstances. A delayed writ petition should not be entertained merely because the appellate remedy has lapsed. The petition was dismissed on that basis, while preserving the taxpayer's ability to file the final return and seek fresh GST registration in accordance with law.
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