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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Sale of scooters to dealer against Form III-A - the sale letters in Forms 20-21 issued by the assessee itself, prove that it had sold the goods to the consumers as, otherwise, the consumers would have no occasion to obtain the sale letters from the assessee - forms III-A were issued by M/s Jyoti Automobiles and accepted by the assessee only to avoid the tax liability - A clear case of collusion between both dealers - no benefit of Form
Sale of scooters to dealer against Form III-A - the sale letters in Forms 20-21 issued by the assessee itself, prove that it had sold the goods to the consumers as, otherwise, the consumers would have no occasion to obtain the sale letters from the assessee - forms III-A were issued by M/s Jyoti Automobiles and accepted by the assessee only to avoid the tax liability - A clear case of collusion between both dealers - no benefit of Form
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