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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Depreciation on plant machinery installed at customer's site free of cost - AO’s objection was that since the equipments in question had not been installed at the assessee’s factory premises, it cannot be said that the equipments were used for the purpose of assessee’s business - Views of the AO cannot sustain - AT
Depreciation on plant machinery installed at customer's site free of cost - AO’s objection was that since the equipments in question had not been installed at the assessee’s factory premises, it cannot be said that the equipments were used for the purpose of assessee’s business - Views of the AO cannot sustain - AT
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