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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Disallowance of socio-economic expense u/s 37 - besides educating the drivers about such disease and the consequent health hazards, what the assessee company is also trying to do is protect the local inhabitants, who are staying in the vicinity of various road highways stretches developed and operated by it, from the floating population of drivers who are prone to such diseases and build a more conducive and healthy environment for smooth functioning of road stretches and has thus established a necessary nexus with its business activities. - Expenses allowed. - AT
Disallowance of socio-economic expense u/s 37 - besides educating the drivers about such disease and the consequent health hazards, what the assessee company is also trying to do is protect the local inhabitants, who are staying in the vicinity of various road highways stretches developed and operated by it, from the floating population of drivers who are prone to such diseases and build a more conducive and healthy environment for smooth functioning of road stretches and has thus established a necessary nexus with its business activities. - Expenses allowed. - AT
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