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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Assessment u/s 158BC - Unexplained investment - Tribunal further has erroneously and perversely held that as question was not asked to the assessee, the assessee cannot be faulted for not furnishing the details and the person to whom the land was sold and only because the assessee was a broker and he was not expected to make investment of his money. It appears that such findings are arrived at by the Tribunal only on the basis of the presumption and assumption - HC
Assessment u/s 158BC - Unexplained investment - Tribunal further has erroneously and perversely held that as question was not asked to the assessee, the assessee cannot be faulted for not furnishing the details and the person to whom the land was sold and only because the assessee was a broker and he was not expected to make investment of his money. It appears that such findings are arrived at by the Tribunal only on the basis of the presumption and assumption - HC
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