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 u/s 14A - non recording of satisfaction - Suo moto disallowances were not commented upon by the Assessing Officer but were completely disregarded and no satisfaction for not accepting the suo moto disallowances was recorded by the AO.AR has also submitted that the disallowances may be restricted to the suo moto disallowance offered by the assessee company. Therefore, we sustain the disallowance u/s 14A, as offered by the assessee company accordingly. - AT
Disallowance u/s 14A - non recording of satisfaction - Suo moto disallowances were not commented upon by the Assessing Officer but were completely disregarded and no satisfaction for not accepting the suo moto disallowances was recorded by the AO.AR has also submitted that the disallowances may be restricted to the suo moto disallowance offered by the assessee company. Therefore, we sustain the disallowance u/s 14A, as offered by the assessee company accordingly. - AT
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