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...
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Welfare-fund contribution deductibility depends on comparing the employer's contribution with gross salary, rather than figures distorted by separate accounting of net salaries and combined employee-employer PF and ESI payments. Contributions remaining within the prescribed ceiling are not treated as excess. Disallowance of expenditure relating to exempt income under section 14A read with rule 8D does not arise where no exempt income is earned. Amounts recovered through customer service bills for canteen and transportation facilities used by deputed employees may qualify as business expenditure when incurred wholly and exclusively for the business and supported by customer-bill records.
Welfare-fund contribution deductibility depends on comparing the employer's contribution with gross salary, rather than figures distorted by separate accounting of net salaries and combined employee-employer PF and ESI payments. Contributions remaining within the prescribed ceiling are not treated as excess. Disallowance of expenditure relating to exempt income under section 14A read with rule 8D does not arise where no exempt income is earned. Amounts recovered through customer service bills for canteen and transportation facilities used by deputed employees may qualify as business expenditure when incurred wholly and exclusively for the business and supported by customer-bill records.
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