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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Prior period expenses are deductible only if the liability crystallised in the relevant year and is supported by evidence; the Tribunal remitted the disallowance for fresh verification. ESOP discount was treated as employee remuneration incurred wholly and exclusively for business, so the deduction was allowed and the disallowance deleted. The demerger loss and depreciation claim failed because the statutory conditions for the resulting company were construed strictly and the required share issuance was not satisfied, so carry forward and set-off were denied. Deferred income recognised under the assessee's consistent accounting method was upheld, as earlier orders in its own case remained binding.
Prior period expenses are deductible only if the liability crystallised in the relevant year and is supported by evidence; the Tribunal remitted the disallowance for fresh verification. ESOP discount was treated as employee remuneration incurred wholly and exclusively for business, so the deduction was allowed and the disallowance deleted. The demerger loss and depreciation claim failed because the statutory conditions for the resulting company were construed strictly and the required share issuance was not satisfied, so carry forward and set-off were denied. Deferred income recognised under the assessee's consistent accounting method was upheld, as earlier orders in its own case remained binding.
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