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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Write-off of dues arising from commodity trading transactions was deductible where the assessee had written the amount off in the profit and loss account during the relevant year and the transactions were undertaken in the ordinary course of business. Contract notes, delivery reports and broker ledger confirmation supported the claim, and the pendency of recovery proceedings did not make it premature. The deduction was allowed as bad debt and, alternatively, as a business loss; the disallowance was deleted.
Write-off of dues arising from commodity trading transactions was deductible where the assessee had written the amount off in the profit and loss account during the relevant year and the transactions were undertaken in the ordinary course of business. Contract notes, delivery reports and broker ledger confirmation supported the claim, and the pendency of recovery proceedings did not make it premature. The deduction was allowed as bad debt and, alternatively, as a business loss; the disallowance was deleted.
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