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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Rejection of books of account under section 145(3) requires specific defects that prevent correct determination of business income; suspicion about cash receipts is insufficient where disclosed turnover and trading results remain undisturbed and computerised books and supporting records are offered for verification. Section 69A does not apply to money recorded in the books merely because the books are formally rejected. Cash deposits within recorded cash balances, arising from disclosed sales and trade-debtor realisations, cannot be assessed again as unexplained income unless their nexus with the recorded business is disproved. The section 69A addition was deleted, with consequential taxation under section 115BBE and penalty proceedings not surviving.
Rejection of books of account under section 145(3) requires specific defects that prevent correct determination of business income; suspicion about cash receipts is insufficient where disclosed turnover and trading results remain undisturbed and computerised books and supporting records are offered for verification. Section 69A does not apply to money recorded in the books merely because the books are formally rejected. Cash deposits within recorded cash balances, arising from disclosed sales and trade-debtor realisations, cannot be assessed again as unexplained income unless their nexus with the recorded business is disproved. The section 69A addition was deleted, with consequential taxation under section 115BBE and penalty proceedings not surviving.
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