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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Exemption u/s. 54 - outer limit for the purchase or construction of the new asset 54(2) - it can safely be gathered that the conscious, purposive and intentional providing by the legislature of “date of furnishing the return of income u/s 139” cannot be substituted and narrowed down to Sec.139(1)- time limit provided for filing of the ‘return of income’ will include return u/s 139(4) as well as the revised return u/s 139(5)
Exemption u/s. 54 - outer limit for the purchase or construction of the new asset 54(2) - it can safely be gathered that the conscious, purposive and intentional providing by the legislature of “date of furnishing the return of income u/s 139” cannot be substituted and narrowed down to Sec.139(1)- time limit provided for filing of the ‘return of income’ will include return u/s 139(4) as well as the revised return u/s 139(5)
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