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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Power to file Revised returns of income pursuant to the scheme of arrangement and amalgamation approved by the NCLT - scheme approved u/s 391 of the Companies Act gives statutory force to enable the assessee to file the revised returns of income beyond limitation u/s 139(5), Circular No. 9 of 2015 issued u/s 119(2)(b) is not applicable and it is not necessary to file revised returns electronically
Power to file Revised returns of income pursuant to the scheme of arrangement and amalgamation approved by the NCLT - scheme approved u/s 391 of the Companies Act gives statutory force to enable the assessee to file the revised returns of income beyond limitation u/s 139(5), Circular No. 9 of 2015 issued u/s 119(2)(b) is not applicable and it is not necessary to file revised returns electronically
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