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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Taxing of capital gain by invoking the provisions of section 50C on the sales of property - the assessee should have rebutted the entire DVO’s report before the CIT(A) by evidence and proper material as to how and why the DVO’s report cannot be relied upon and the assessee’s sale value is actually the fair market value. Here such an exercise has not been done by the assessee - AT
Taxing of capital gain by invoking the provisions of section 50C on the sales of property - the assessee should have rebutted the entire DVO’s report before the CIT(A) by evidence and proper material as to how and why the DVO’s report cannot be relied upon and the assessee’s sale value is actually the fair market value. Here such an exercise has not been done by the assessee - AT
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