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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Non-debit of partners' remuneration and interest did not affect eligibility for deduction under section 10AA where the resulting business profit remained eligible, so the deletion of the addition was justified. The note also records that reassessment cannot travel beyond the recorded reasons: reopening was based on discrepancy in import figures, no addition was made on that issue, and the addition on partners' remuneration and interest was outside the permissible scope. The Revenue's appeal was dismissed on both grounds.
Non-debit of partners' remuneration and interest did not affect eligibility for deduction under section 10AA where the resulting business profit remained eligible, so the deletion of the addition was justified. The note also records that reassessment cannot travel beyond the recorded reasons: reopening was based on discrepancy in import figures, no addition was made on that issue, and the addition on partners' remuneration and interest was outside the permissible scope. The Revenue's appeal was dismissed on both grounds.
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