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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Genuineness of expenses - although the said expenditure was not fully supported by the relevant supporting documentary evidence as pointed out by the authorities below making it unverifiable, the same cannot be entirely disallowed keeping in view the nature of the assessee’s business and it would be fair and reasonable to disallow the said expenditure to the extent of 50% for the unverifiable element involved therein.
Genuineness of expenses - although the said expenditure was not fully supported by the relevant supporting documentary evidence as pointed out by the authorities below making it unverifiable, the same cannot be entirely disallowed keeping in view the nature of the assessee’s business and it would be fair and reasonable to disallow the said expenditure to the extent of 50% for the unverifiable element involved therein.
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