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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Denying credit for tax deducted at source in the hands of company - income is credited to the bank account held in the name of one of the director, credit for TDS in respect of the additional incentive is reflected in the Form 26AS of the director - it would be grossly unfair and unjust to deny the assessee the credit of TDS where the corresponding income has been assessed in its hand - AT
Denying credit for tax deducted at source in the hands of company - income is credited to the bank account held in the name of one of the director, credit for TDS in respect of the additional incentive is reflected in the Form 26AS of the director - it would be grossly unfair and unjust to deny the assessee the credit of TDS where the corresponding income has been assessed in its hand - AT
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