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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Unexplained expenditure under section 69C - allegation that, 18340 kilograms of wheat flour was purchased from the open market and had not shown the purchase cost of 123750 kilograms of wheat flour - the purchase of stock of such atta was reflected in the wheat purchase account and not in the atta purchase account. The Commissioner (Appeals) noted that the assessee had submitted documentary evidence to demonstrate the same, which was found to be correct - No addition can be made - HC
Unexplained expenditure under section 69C - allegation that, 18340 kilograms of wheat flour was purchased from the open market and had not shown the purchase cost of 123750 kilograms of wheat flour - the purchase of stock of such atta was reflected in the wheat purchase account and not in the atta purchase account. The Commissioner (Appeals) noted that the assessee had submitted documentary evidence to demonstrate the same, which was found to be correct - No addition can be made - HC
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