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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Validity of assessment u/s 153C - real owner of the document seized - the presumption cast under provisions of section 132(4A) of the Act, comes into play. - even the provisions of section 292C(1) also provide the same. This presumption was not rebutted by the AO of the searched person - assessee-firm cannot be said to be the owner of the document seized. - AT
Validity of assessment u/s 153C - real owner of the document seized - the presumption cast under provisions of section 132(4A) of the Act, comes into play. - even the provisions of section 292C(1) also provide the same. This presumption was not rebutted by the AO of the searched person - assessee-firm cannot be said to be the owner of the document seized. - AT
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