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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Refund - unjust enrichment - The mere fact that the service tax amount have not been in the clients ledger account, and that the service tax amount paid has been accounted as an expenses in profit and loss account cannot override the factual position that whatever billing has been made is inclusive of service tax which is not shown separately - refund allowed - AT
Refund - unjust enrichment - The mere fact that the service tax amount have not been in the clients ledger account, and that the service tax amount paid has been accounted as an expenses in profit and loss account cannot override the factual position that whatever billing has been made is inclusive of service tax which is not shown separately - refund allowed - AT
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