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 271G - failure to furnish documentation as required under the Rule 10D(1) and Section 92D(3) - the assessee had substantially complied with the directions of the TPO and had placed on his record the requisite information to the extent the same was practically possible in light of the very nature of its trade - not effecting absolute compliance on account of practical difficulties is a reasonable cause within the realm of Sec. 273B - no penalty
Penalty u/s 271G - failure to furnish documentation as required under the Rule 10D(1) and Section 92D(3) - the assessee had substantially complied with the directions of the TPO and had placed on his record the requisite information to the extent the same was practically possible in light of the very nature of its trade - not effecting absolute compliance on account of practical difficulties is a reasonable cause within the realm of Sec. 273B - no penalty
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