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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Allowability of loss on demerger in the computation of book profit u/s 115JB - MAT - the observation of the AO that such loss could not be debited to the profit and loss account and ought to have been adjusted against the reserve of the assessee company is not Correct - AT
Allowability of loss on demerger in the computation of book profit u/s 115JB - MAT - the observation of the AO that such loss could not be debited to the profit and loss account and ought to have been adjusted against the reserve of the assessee company is not Correct - AT
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