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 u/s 68 - search u/s 132(1) - amount received on the occasion of marriage of his brother-in-law’s daughter or as commission income - merely because the assessee is inconsistent in his explanation does not ifso facto and on its own alone lead to the conclusion that a particular noting represents the income of the assessee. There has to be some material on record, more importantly, in the absence of any explanation by the assessee, to form the basis of making the addition.
Addition u/s 68 - search u/s 132(1) - amount received on the occasion of marriage of his brother-in-law’s daughter or as commission income - merely because the assessee is inconsistent in his explanation does not ifso facto and on its own alone lead to the conclusion that a particular noting represents the income of the assessee. There has to be some material on record, more importantly, in the absence of any explanation by the assessee, to form the basis of making the addition.
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