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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Assessment by Mumbai AO - The jurisdiction would lie with the Income Tax Authorities at New Delhi. - This was brushed aside only on the ground that the assessment was getting time barred on 31 March 2011 and it was now not possible to transfer the case papers to the Authorities at New Delhi - Assessment is invalid.... - HC
Assessment by Mumbai AO - The jurisdiction would lie with the Income Tax Authorities at New Delhi. - This was brushed aside only on the ground that the assessment was getting time barred on 31 March 2011 and it was now not possible to transfer the case papers to the Authorities at New Delhi - Assessment is invalid.... - HC
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