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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Disallowance of interest expenses - assessee has made contradictory submissions before the learned CIT (A) and has not furnished the required details of the interest expenses to justify that the interest cost was incurred in the course of the business. Thus in the absence of sufficient documentary evidence about the interest expenses on the borrowed fund whether the same was utilized for the purpose of business, claim of assessee cannot be allowed- AT
Disallowance of interest expenses - assessee has made contradictory submissions before the learned CIT (A) and has not furnished the required details of the interest expenses to justify that the interest cost was incurred in the course of the business. Thus in the absence of sufficient documentary evidence about the interest expenses on the borrowed fund whether the same was utilized for the purpose of business, claim of assessee cannot be allowed- AT
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