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...
RBI regulatory monetary levies for non-compliance with lending guidelines may be deductible where the underlying default is supervisory in an otherwise lawful banking business, rather than an offence or prohibited activity; the levy was therefore not disallowed under Explanation 1 to section 37(1). Banking-company securities held as stock-in-trade did not attract expenditure disallowance for exempt dividend income under section 14A and Rule 8D. Net depreciation on investments valued under ICDS VIII and RBI guidelines was allowable because the prescribed method was followed. Employee stock-option discount was treated as revenue expenditure because it incentivises and retains employees without creating an enduring asset or constituting capital-raising expenditure.
RBI regulatory monetary levies for non-compliance with lending guidelines may be deductible where the underlying default is supervisory in an otherwise lawful banking business, rather than an offence or prohibited activity; the levy was therefore not disallowed under Explanation 1 to section 37(1). Banking-company securities held as stock-in-trade did not attract expenditure disallowance for exempt dividend income under section 14A and Rule 8D. Net depreciation on investments valued under ICDS VIII and RBI guidelines was allowable because the prescribed method was followed. Employee stock-option discount was treated as revenue expenditure because it incentivises and retains employees without creating an enduring asset or constituting capital-raising expenditure.
Note: It is a system-generated summary and is for quick reference only.