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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Addition u/s 40A(3) - cash payments were made to truck drivers after banking hours - even this amount should not have been disallowed u/s 40A(3) read with Rule 6DD of the Income-Tax Rules as the CIT(A) had observed in respect of payments made to truck drivers where he deleted the part cash payment. In that matter, the CIT(A) was not justified in confirming part additions under the same set of facts - AT
Addition u/s 40A(3) - cash payments were made to truck drivers after banking hours - even this amount should not have been disallowed u/s 40A(3) read with Rule 6DD of the Income-Tax Rules as the CIT(A) had observed in respect of payments made to truck drivers where he deleted the part cash payment. In that matter, the CIT(A) was not justified in confirming part additions under the same set of facts - AT
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