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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Valuation - sale of Gypsum - mere bifurcation of the sale price of the goods in a mutual contract between the parties under a separate bargain or even a common bargain will not be material and so long as the contract of sale is "F.O.R. Destination" and the contract of sale of goods results in the transfer of property of goods at the door steps of the buyer, all pre-sale expenses incurred by the selling dealer will be part of the sale price or taxable turnover.
Valuation - sale of Gypsum - mere bifurcation of the sale price of the goods in a mutual contract between the parties under a separate bargain or even a common bargain will not be material and so long as the contract of sale is "F.O.R. Destination" and the contract of sale of goods results in the transfer of property of goods at the door steps of the buyer, all pre-sale expenses incurred by the selling dealer will be part of the sale price or taxable turnover.
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