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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Rectification of mistake u/s 254 - dismissal of Revenue’s appeal for low tax effect - Tribunal failed to note that para 10(c) of CBDT Circular which state that Revenue would contest appeals in respect of orders which were the result of the Department’s acceptance of Revenue audit objections, even if the tax effect in such appeal is lower than the prescribed limit - mistake apparent on record
Rectification of mistake u/s 254 - dismissal of Revenue’s appeal for low tax effect - Tribunal failed to note that para 10(c) of CBDT Circular which state that Revenue would contest appeals in respect of orders which were the result of the Department’s acceptance of Revenue audit objections, even if the tax effect in such appeal is lower than the prescribed limit - mistake apparent on record
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