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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Penalty u/s 271(1)(c) - difference of income in the return filed u/s.139(1) and 153A - there was no such allegation that of assessee was found to be the owner of any money, bullion, jewellery or other valuable article or thing or any income based on any entry in any books of account or other documents or transactions, either in the assessment or penalty or the CIT (A) order - no penalty 271 (1) (c) r.w. the explanation 5A merely on the basis of the statement u/s 132(4)
Penalty u/s 271(1)(c) - difference of income in the return filed u/s.139(1) and 153A - there was no such allegation that of assessee was found to be the owner of any money, bullion, jewellery or other valuable article or thing or any income based on any entry in any books of account or other documents or transactions, either in the assessment or penalty or the CIT (A) order - no penalty 271 (1) (c) r.w. the explanation 5A merely on the basis of the statement u/s 132(4)
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