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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Personal liability of administrator of trust for non deduction of tax at source - Principal Officers - The proceedings initiated is not a criminal proceeding. Under these circumstances the impugned proceedings could not have been initiated against the Administrator, who was only acting as an employee of the Trust, as no payments were made to in his individual capacity and the payments were made by the Trust. - HC
Personal liability of administrator of trust for non deduction of tax at source - Principal Officers - The proceedings initiated is not a criminal proceeding. Under these circumstances the impugned proceedings could not have been initiated against the Administrator, who was only acting as an employee of the Trust, as no payments were made to in his individual capacity and the payments were made by the Trust. - HC
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