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 cash credits u/s 68 - Once the PAN and confirmation letters are placed before the AO, it is for the AO to establish that the creditor has no capacity to make the advance and the loan is ingenuine - it is also incorrect to hold that every assessee should run behind the creditors and parade them before the AO after furnishing the confirmation letters - assessee has discharged the burden u/s 68
Addition of cash credits u/s 68 - Once the PAN and confirmation letters are placed before the AO, it is for the AO to establish that the creditor has no capacity to make the advance and the loan is ingenuine - it is also incorrect to hold that every assessee should run behind the creditors and parade them before the AO after furnishing the confirmation letters - assessee has discharged the burden u/s 68
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