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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Assessment u/s 153A - claim of deduction under section 80IA(4) - Paper company or not - assessee as a SPV was a mandatory requirement of NHAI - four laning of the existing road - to be considered as a new infrastructure facility or not - AO directed to verify the correctness of assessee's computation of deduction u/s 80IA and allow the same. Further, to ensure that deduction for the same infrastructure facility is not allowed to both the assessee and Gil, the Assessing Officer is directed to verify the relevant facts and thereafter compute deduction u/s 80IA. - AT
Assessment u/s 153A - claim of deduction under section 80IA(4) - Paper company or not - assessee as a SPV was a mandatory requirement of NHAI - four laning of the existing road - to be considered as a new infrastructure facility or not - AO directed to verify the correctness of assessee's computation of deduction u/s 80IA and allow the same. Further, to ensure that deduction for the same infrastructure facility is not allowed to both the assessee and Gil, the Assessing Officer is directed to verify the relevant facts and thereafter compute deduction u/s 80IA. - AT
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