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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Revisionary jurisdiction cannot be invoked merely because a more extensive enquiry is preferred where the Assessing Officer has examined the deduction claim, obtained the statutory audit report and employee-wise details, issued a proposed disallowance notice, and considered the response. Revision requires an erroneous assessment that is prejudicial to Revenue, not simply an allegedly inadequate enquiry. Deduction eligibility is not denied solely because a staffing employer deploys workers at client premises, where it recruits, appoints, pays, reassigns and fulfils statutory employment obligations. Client supervision and salary reimbursement alone do not displace the employer-employee relationship. On these facts, revision for fresh examination was impermissible and the assessment was restored.
Revisionary jurisdiction cannot be invoked merely because a more extensive enquiry is preferred where the Assessing Officer has examined the deduction claim, obtained the statutory audit report and employee-wise details, issued a proposed disallowance notice, and considered the response. Revision requires an erroneous assessment that is prejudicial to Revenue, not simply an allegedly inadequate enquiry. Deduction eligibility is not denied solely because a staffing employer deploys workers at client premises, where it recruits, appoints, pays, reassigns and fulfils statutory employment obligations. Client supervision and salary reimbursement alone do not displace the employer-employee relationship. On these facts, revision for fresh examination was impermissible and the assessment was restored.
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