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 on account of non-reconciliation of Form 26AS - business of advertisement agency - the assessee reports only the commission portion as its income in its P & L account and not the gross receipts, hence, there is always bound to be difference with regard to the amounts reflected in the Form 26AS vis-à-vis books of accounts - the explanation is reasonable and it is highly impracticable for reconciling the same in this scenario - no addition
Addition on account of non-reconciliation of Form 26AS - business of advertisement agency - the assessee reports only the commission portion as its income in its P & L account and not the gross receipts, hence, there is always bound to be difference with regard to the amounts reflected in the Form 26AS vis-à-vis books of accounts - the explanation is reasonable and it is highly impracticable for reconciling the same in this scenario - no addition
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