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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Commission expenditure - When the primarily evidence of nature of services rendered for which Assessee paid commission is not on record, it is not possible to say whether the expenditure was wholly and exclusively incurred for the purpose of business and also as to whether explanation to Sec.37(1) of the Act would be attracted. - AT
Commission expenditure - When the primarily evidence of nature of services rendered for which Assessee paid commission is not on record, it is not possible to say whether the expenditure was wholly and exclusively incurred for the purpose of business and also as to whether explanation to Sec.37(1) of the Act would be attracted. - AT
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