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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Nature of subsidy received - Capital or revenue receipt - Though the principles of res judicata doesn’t apply in the income tax proceedings, however, it has also been laid down by the Courts that unless there are changes in the facts and circumstances of the case, past consistent position so adopted should not be disturbed
Nature of subsidy received - Capital or revenue receipt - Though the principles of res judicata doesn’t apply in the income tax proceedings, however, it has also been laid down by the Courts that unless there are changes in the facts and circumstances of the case, past consistent position so adopted should not be disturbed
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