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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
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Numerical entries in seized records may be read by appending zeros only where the interpretation is supported by the nature of the entries and surrounding material. The High Court restored the addition based on the Commissioner (Appeals)' reasoned interpretation of pages 4 and 5 of Annexure B-3, holding that the Tribunal could not append a single zero after rejecting larger multipliers without reasons. Additions for unexplained investment and undisclosed profit from other rough-diamond entries were deleted because those transactions had already been considered for taxation in another entity's assessment and the assessee lacked financial capacity to conduct the business independently. Revenue appeals were partly allowed.
Numerical entries in seized records may be read by appending zeros only where the interpretation is supported by the nature of the entries and surrounding material. The High Court restored the addition based on the Commissioner (Appeals)' reasoned interpretation of pages 4 and 5 of Annexure B-3, holding that the Tribunal could not append a single zero after rejecting larger multipliers without reasons. Additions for unexplained investment and undisclosed profit from other rough-diamond entries were deleted because those transactions had already been considered for taxation in another entity's assessment and the assessee lacked financial capacity to conduct the business independently. Revenue appeals were partly allowed.
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