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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Disallowance u/s 37(1) - payments of expenditure by way of cash - Assessee has incurred 90% of expenses by way of cheque, meaning thereby, in case of business necessity only the assessee has been incurring expenses by way of cash. - Since the vouchers form part of regular books of accounts maintained by the assessee, the same cannot be considered as additional evidences. - this issue may be put to rest by disallowing 5% of expenses incurred by way of cash exceeding ₹ 20,000/-
Disallowance u/s 37(1) - payments of expenditure by way of cash - Assessee has incurred 90% of expenses by way of cheque, meaning thereby, in case of business necessity only the assessee has been incurring expenses by way of cash. - Since the vouchers form part of regular books of accounts maintained by the assessee, the same cannot be considered as additional evidences. - this issue may be put to rest by disallowing 5% of expenses incurred by way of cash exceeding ₹ 20,000/-
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