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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On notice being sent to the dealer, if the dealer files his objections, then it is for the AO to independently apply his mind to the objections and then rule on the objections. While doing so, the AO cannot state that he has been directed by the Inspecting Officer to implement a proposal - HC
On notice being sent to the dealer, if the dealer files his objections, then it is for the AO to independently apply his mind to the objections and then rule on the objections. While doing so, the AO cannot state that he has been directed by the Inspecting Officer to implement a proposal - HC
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