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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Exemption u/s 11 - CIT-A observed that proceeds of kuri business in the case of the assessee substantially benefited the members or subscribers and the predominant object was to generate profit in the hands of subscribers - The activity carried on by the assessee-Trust in the form of kuri business is hit by the proviso to section 2(15) - exemption cannot be allowed - AT
Exemption u/s 11 - CIT-A observed that proceeds of kuri business in the case of the assessee substantially benefited the members or subscribers and the predominant object was to generate profit in the hands of subscribers - The activity carried on by the assessee-Trust in the form of kuri business is hit by the proviso to section 2(15) - exemption cannot be allowed - AT
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