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...
Interest on enhanced compensation for compulsorily acquired agricultural land is taxable under the provisions governing such interest where binding jurisdictional precedent so requires. Rectification is limited to mistakes apparent from the record and cannot be used to review, modify, or avoid binding jurisdictional precedent on the basis of a contrary Coordinate Bench view; relief through rectification is therefore unavailable. Where the interest is taxable as income from other sources, the statutory fifty per cent deduction must be allowed. Taxable interest must consequently be computed after granting that deduction where it has not already been provided.
Interest on enhanced compensation for compulsorily acquired agricultural land is taxable under the provisions governing such interest where binding jurisdictional precedent so requires. Rectification is limited to mistakes apparent from the record and cannot be used to review, modify, or avoid binding jurisdictional precedent on the basis of a contrary Coordinate Bench view; relief through rectification is therefore unavailable. Where the interest is taxable as income from other sources, the statutory fifty per cent deduction must be allowed. Taxable interest must consequently be computed after granting that deduction where it has not already been provided.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
