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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Valuation - the benefit accruing to the appellant by way of extending the benefit of concessional rate of duty for import of components is to be considered as additional consideration flowing from the buyer to the appellant. The charging of differential duty on such consideration confirmed - AT
Valuation - the benefit accruing to the appellant by way of extending the benefit of concessional rate of duty for import of components is to be considered as additional consideration flowing from the buyer to the appellant. The charging of differential duty on such consideration confirmed - AT
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