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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DSIR-certified capital scientific research expenditure qualified for weighted deduction at 200%, and the Tribunal directed allowance of the balance deduction where only 100% had been given on the certified amount. For uncertified capital expenditure, it held that once the expenditure was actually incurred for scientific research and that fact was undisputed, denial of weighted deduction did not bar a normal deduction under section 35(1)(iv); the Assessing Officer was directed to verify and allow it. On transfer pricing, the deletion of the adjustment was sustained because no defect was shown in the assessee's study, third-party finished-goods margins were not a proper benchmark for inter-unit transfers, and no fresh material distinguished the year from earlier years. The consequential section 80IC relief was also upheld.
DSIR-certified capital scientific research expenditure qualified for weighted deduction at 200%, and the Tribunal directed allowance of the balance deduction where only 100% had been given on the certified amount. For uncertified capital expenditure, it held that once the expenditure was actually incurred for scientific research and that fact was undisputed, denial of weighted deduction did not bar a normal deduction under section 35(1)(iv); the Assessing Officer was directed to verify and allow it. On transfer pricing, the deletion of the adjustment was sustained because no defect was shown in the assessee's study, third-party finished-goods margins were not a proper benchmark for inter-unit transfers, and no fresh material distinguished the year from earlier years. The consequential section 80IC relief was also upheld.
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