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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The assessee has been granted interest under section 244A of the Income-tax Act as due to him and the calculation of the interest was not disputed by the assessee. The assessee cannot widen the scope of the provisions of section 154 by putting various debatable issues - AT
The assessee has been granted interest under section 244A of the Income-tax Act as due to him and the calculation of the interest was not disputed by the assessee. The assessee cannot widen the scope of the provisions of section 154 by putting various debatable issues - AT
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