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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Classification of services - adjudicating authority held the assessee have not been engaged in the activity of Site Formation and Clearances, Excavation and Earth moving service but only supplying earth moving machines like excavators etc. on rental basis and the physical control and possession of these machines have always remained with the clients who hired such machines - the department has not adduced any evidence to controvert the finding - demand quashed
Classification of services - adjudicating authority held the assessee have not been engaged in the activity of Site Formation and Clearances, Excavation and Earth moving service but only supplying earth moving machines like excavators etc. on rental basis and the physical control and possession of these machines have always remained with the clients who hired such machines - the department has not adduced any evidence to controvert the finding - demand quashed
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