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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Adding back of interest waiver to the book profit u/s. 115JB - CIT invoked the provisions of section 263 - the Assessing Officer having computed the income of the assessee in accordance with the normal provisions of the Act, thus cannot hold that the assessment order passed is erroneous so far as prejudicial to the interest of revenue - AT
Adding back of interest waiver to the book profit u/s. 115JB - CIT invoked the provisions of section 263 - the Assessing Officer having computed the income of the assessee in accordance with the normal provisions of the Act, thus cannot hold that the assessment order passed is erroneous so far as prejudicial to the interest of revenue - AT
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