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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Transshipment of ship stores - Merely because as on the date of transfer of ship stores to the newly built vessel SV Shivam, which was not ready for voyage, the transfer of ship stores under Section 86 and later consumed on board as per Sec. 87, becomes incorrect and duty could be recovered on the ship stores, cannot be sustained. - AT
Transshipment of ship stores - Merely because as on the date of transfer of ship stores to the newly built vessel SV Shivam, which was not ready for voyage, the transfer of ship stores under Section 86 and later consumed on board as per Sec. 87, becomes incorrect and duty could be recovered on the ship stores, cannot be sustained. - AT
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