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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Addition on account of under valuation of closing stock of Yarn - none of the authorities below have given direction to revise the value of the opening stock of the subsequent year. Thus in the absence of such direction, addition made for the year under consideration will again be taxed in the subsequent assessment year which is not desirable as the same income should not be taxed twice under the provisions of the Act.
Addition on account of under valuation of closing stock of Yarn - none of the authorities below have given direction to revise the value of the opening stock of the subsequent year. Thus in the absence of such direction, addition made for the year under consideration will again be taxed in the subsequent assessment year which is not desirable as the same income should not be taxed twice under the provisions of the Act.
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