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...
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Additional documentary evidence on the GST refund mismatch was admitted as vital to verifying its accounting and tax treatment. Because the evidence required verification by the Assessing Officer and the Revenue did not oppose admission, the adjustment reducing the returned business loss was set aside and remanded for fresh adjudication after a hearing. Outstanding trade payables arising from purchases could not be treated as unexplained cash credit where creditor-balance differences had been reconciled and supported by documentary evidence. In the absence of contrary material or precedent from the Revenue, deletion of that addition was upheld and the Revenue's appeal was dismissed.
Additional documentary evidence on the GST refund mismatch was admitted as vital to verifying its accounting and tax treatment. Because the evidence required verification by the Assessing Officer and the Revenue did not oppose admission, the adjustment reducing the returned business loss was set aside and remanded for fresh adjudication after a hearing. Outstanding trade payables arising from purchases could not be treated as unexplained cash credit where creditor-balance differences had been reconciled and supported by documentary evidence. In the absence of contrary material or precedent from the Revenue, deletion of that addition was upheld and the Revenue's appeal was dismissed.
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