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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Non recording of finding of facts - income from sale of shares - What the assessee had to prove before the lower adjudication authorities was that it continued to be an investor in current AY. This finding of fact has not been entered at any stage of the proceedings. - impugned order of the tribunal is erroneous and perverse, give rise a substantial question of law - matter remanded
Non recording of finding of facts - income from sale of shares - What the assessee had to prove before the lower adjudication authorities was that it continued to be an investor in current AY. This finding of fact has not been entered at any stage of the proceedings. - impugned order of the tribunal is erroneous and perverse, give rise a substantial question of law - matter remanded
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