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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Book profit u/s 115JB - MAT - the profit on sale of assets credited to the profit & loss account cannot be excluded while computing the Book Profit under section 115JB even though the capital gains arising from the sale of that asset is not subject to tax under the normal provisions of the Income-tax Act by virtue of the provisions of section 54EC... - AT
Book profit u/s 115JB - MAT - the profit on sale of assets credited to the profit & loss account cannot be excluded while computing the Book Profit under section 115JB even though the capital gains arising from the sale of that asset is not subject to tax under the normal provisions of the Income-tax Act by virtue of the provisions of section 54EC... - AT
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