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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Flood rehabilitation housing expenditure may qualify as business expenditure where incurred under a State Government memorandum for commercial expediency and long-term business benefit; that issue was remitted for fresh consideration in line with jurisdictional High Court rulings. Ad hoc disallowances of vehicle hire, transport charges and repairs to leasehold premises were deleted because the assessee produced bills, PANs, ledgers and other supporting records, and no objective basis for estimation was shown. Interest reflected in Form 26AS was not taxed on accrual absent reasonable certainty of receipt, and TDS credit was shifted to the year of actual offer. Customs duty liability crystallised on demand and was allowable on payment, infrastructure sharing charges were accepted as business expenditure, and customer advances were not taxed under cessation of liability principles because no remission occurred.
Flood rehabilitation housing expenditure may qualify as business expenditure where incurred under a State Government memorandum for commercial expediency and long-term business benefit; that issue was remitted for fresh consideration in line with jurisdictional High Court rulings. Ad hoc disallowances of vehicle hire, transport charges and repairs to leasehold premises were deleted because the assessee produced bills, PANs, ledgers and other supporting records, and no objective basis for estimation was shown. Interest reflected in Form 26AS was not taxed on accrual absent reasonable certainty of receipt, and TDS credit was shifted to the year of actual offer. Customs duty liability crystallised on demand and was allowable on payment, infrastructure sharing charges were accepted as business expenditure, and customer advances were not taxed under cessation of liability principles because no remission occurred.
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