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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Reassessment u/s 148 - reasons recorded should show in what manner the assessee had failed to make a full and true disclosure of all material facts necessary for the assessment, it is not mere irregularity but it would render the reopening of assessment after four year invalid as First proviso to section 147 is applicable - assessment quashed
Reassessment u/s 148 - reasons recorded should show in what manner the assessee had failed to make a full and true disclosure of all material facts necessary for the assessment, it is not mere irregularity but it would render the reopening of assessment after four year invalid as First proviso to section 147 is applicable - assessment quashed
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