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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Addition of commission income - accommodation entry provider - commission income with respect to the transaction entered into by the entry operator are required to be taxed in the hands of the assessee company, provided the same have already not been taxed in the hands of entry operator otherwise it will amount to double addition - remanded to AO to ascertain this fact
Addition of commission income - accommodation entry provider - commission income with respect to the transaction entered into by the entry operator are required to be taxed in the hands of the assessee company, provided the same have already not been taxed in the hands of entry operator otherwise it will amount to double addition - remanded to AO to ascertain this fact
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