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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Penalty u/s 271B - not getting accounts audited u/s 44AB - No doubt, exemption claimed by the assessee society trust u/s 11A has not been granted by the AO and completed the assessment u/s 143(3) but it will not burden the assessee to get its account audited with retrospective effect so long as registration u/s 12A of the Act is in operation - AT
Penalty u/s 271B - not getting accounts audited u/s 44AB - No doubt, exemption claimed by the assessee society trust u/s 11A has not been granted by the AO and completed the assessment u/s 143(3) but it will not burden the assessee to get its account audited with retrospective effect so long as registration u/s 12A of the Act is in operation - AT
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