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...
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Inadvertent filing of the concessional-regime option form by a credit co-operative society does not, by itself, require assessment under that regime where the return was filed under the old regime, claimed the statutory deduction available to credit co-operative societies, and expressly stated that no concessional-regime option was exercised. The filing was not treated as an attempted withdrawal of an option after filing a return under the new regime. Processing the return under the concessional regime and disallowing the deduction were unjustified; the appellate order was set aside and the deduction claim was accepted.
Inadvertent filing of the concessional-regime option form by a credit co-operative society does not, by itself, require assessment under that regime where the return was filed under the old regime, claimed the statutory deduction available to credit co-operative societies, and expressly stated that no concessional-regime option was exercised. The filing was not treated as an attempted withdrawal of an option after filing a return under the new regime. Processing the return under the concessional regime and disallowing the deduction were unjustified; the appellate order was set aside and the deduction claim was accepted.
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