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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Levy of penalty - It is not actual evasion of tax as contemplated in the books, but it is an attempt. Probably it might be an omission. But as far as the Department is concerned, the reasonable view that the Department could take is that there is an attempt to evade tax. - Levy of penalty confirmied equal to the amount of tax.
Levy of penalty - It is not actual evasion of tax as contemplated in the books, but it is an attempt. Probably it might be an omission. But as far as the Department is concerned, the reasonable view that the Department could take is that there is an attempt to evade tax. - Levy of penalty confirmied equal to the amount of tax.
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