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...
TNMM aggregation prevented separate benchmarking of IT support services where accepted segmental margins already included the associated-enterprise markup and the services were inextricably linked to the core business. The transfer-pricing adjustment on the IT support-services margin was deleted. Notional interest on overdue associated-enterprise receivables was unwarranted because the taxpayer was debt-free, incurred no significant interest cost, and no new material justified departure from earlier treatment; the related adjustment was deleted. Capital expenditure on an in-house scientific-research facility remained deductible under section 35(1)(iv) despite the concessional tax regime and absence of valid Form 3CM, which was relevant to section 35(2AB), not section 35(1)(iv).
TNMM aggregation prevented separate benchmarking of IT support services where accepted segmental margins already included the associated-enterprise markup and the services were inextricably linked to the core business. The transfer-pricing adjustment on the IT support-services margin was deleted. Notional interest on overdue associated-enterprise receivables was unwarranted because the taxpayer was debt-free, incurred no significant interest cost, and no new material justified departure from earlier treatment; the related adjustment was deleted. Capital expenditure on an in-house scientific-research facility remained deductible under section 35(1)(iv) despite the concessional tax regime and absence of valid Form 3CM, which was relevant to section 35(2AB), not section 35(1)(iv).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
