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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With effect from 1.5.2006, the words “commercial concern" was substituted by the words “person" and w.e.f 16.5.2008, the words “to a client” was replaced by the word “to any person”. There is no dispute that appellants are a charitable, non-profit organization and for the period at least upto 1.5.2006, appellant cannot be called a “commercial concern” - AT
With effect from 1.5.2006, the words “commercial concern" was substituted by the words “person" and w.e.f 16.5.2008, the words “to a client” was replaced by the word “to any person”. There is no dispute that appellants are a charitable, non-profit organization and for the period at least upto 1.5.2006, appellant cannot be called a “commercial concern” - AT
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