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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Import of fabric - undervaluation of imported goods - evasion of customs duty - once the assessments finally done have not been challenged by way of filing an appeal there again, it was not open to the revenue to initiate the proceedings by invoking the longer period of limitation.
Import of fabric - undervaluation of imported goods - evasion of customs duty - once the assessments finally done have not been challenged by way of filing an appeal there again, it was not open to the revenue to initiate the proceedings by invoking the longer period of limitation.
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