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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Interest attributed to the funds diverted to sister-concern - Since no fresh advances were given during the relevant assessment year to the sister concern and when no addition on this account was made in the earlier assessment years or in the subsequent assessment years no addition can be made on a notional basis to the interest income under the head `income from other sources’.
Interest attributed to the funds diverted to sister-concern - Since no fresh advances were given during the relevant assessment year to the sister concern and when no addition on this account was made in the earlier assessment years or in the subsequent assessment years no addition can be made on a notional basis to the interest income under the head `income from other sources’.
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