Belated Form 10B filing during Covid-19 cannot defeat charitable exemption where genuine hardship warrants condonation and substantial justice prevail...
Limitation for consequential assessments runs from prescribed authority receipt, while verified purchases cannot be disallowed merely for unanswered s...
Higher depreciation for qualifying commercial vehicles, exempt-income disallowance, research deduction verification, and club-expense treatment clarif...
Charitable registration renewal cannot become an assessment of receipts, profitability or annual exemption compliance, requiring renewal and donation ...
AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjust...
Segmental aggregation under TNMM prevents a separate nil arm's length price adjustment for intra-group back-office, sales and marketing support services that are integral operating costs of subscription and services segments under an assured-margin model; a separate adjustment would duplicate the segment-level benchmarking. Working capital adjustment must be allowed where differing working-capital levels materially affect comparable margins, despite unavailable daily public balances, subject to verification. Comparable selection requires functional similarity: product developers, education providers, companies with proprietary products or intangibles, diversified operations, entrepreneurial risks, or absent segmental data should be excluded from routine service-provider benchmarks. TDS credit must be allowed, interest under section 234A is not leviable on the stated facts, and consequential tax computation is required.
Segmental aggregation under TNMM prevents a separate nil arm's length price adjustment for intra-group back-office, sales and marketing support services that are integral operating costs of subscription and services segments under an assured-margin model; a separate adjustment would duplicate the segment-level benchmarking. Working capital adjustment must be allowed where differing working-capital levels materially affect comparable margins, despite unavailable daily public balances, subject to verification. Comparable selection requires functional similarity: product developers, education providers, companies with proprietary products or intangibles, diversified operations, entrepreneurial risks, or absent segmental data should be excluded from routine service-provider benchmarks. TDS credit must be allowed, interest under section 234A is not leviable on the stated facts, and consequential tax computation is required.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
