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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Deemed dividend - Buy back of shares / reduction in share capital - amount remitted to non-residents - Determination of liability of the appellant u/s 115-O - as submitted that the appellant was never put to notice about the proposed determination - The communication dated 22.03.2018 shall be treated as a show cause notice calling upon the appellant to respond with regard to the aspects adverted to in said communication. The appellant shall be entitled to put in its reply and place such material - SC
Deemed dividend - Buy back of shares / reduction in share capital - amount remitted to non-residents - Determination of liability of the appellant u/s 115-O - as submitted that the appellant was never put to notice about the proposed determination - The communication dated 22.03.2018 shall be treated as a show cause notice calling upon the appellant to respond with regard to the aspects adverted to in said communication. The appellant shall be entitled to put in its reply and place such material - SC
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