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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Illegal attempt for exportation - It appears that the investigation agency could not prove beyond doubt that the goods were actually attempted to export illegally to Nepal. The activities of the appellants may be suspicious but not enough to hold charge of attempted to export in the absence of positive evidence - AT
Illegal attempt for exportation - It appears that the investigation agency could not prove beyond doubt that the goods were actually attempted to export illegally to Nepal. The activities of the appellants may be suspicious but not enough to hold charge of attempted to export in the absence of positive evidence - AT
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