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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Attachment orders - to declare transfers to be void - If the declaration of nullity and voidity under Section 281(1) is automatic, then there is no necessity for the Law Makers to empower the Income Tax Officer to pass an order of attachment under Rule 48 prohibiting all transfers and the creation of charge on the properties.
Attachment orders - to declare transfers to be void - If the declaration of nullity and voidity under Section 281(1) is automatic, then there is no necessity for the Law Makers to empower the Income Tax Officer to pass an order of attachment under Rule 48 prohibiting all transfers and the creation of charge on the properties.
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