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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Special audit u/s 142(2A) - extension of 60 days for conduct of special audit - no extension has been given by AO but by the Commissioner and the AO has only conveyed the approval, therefore, we hold that the grant of extension by the Commissioner is beyond the powers enshrined under the statute. Accordingly, the assessment completed after the due date is held to be void-ab-initio - AT
Special audit u/s 142(2A) - extension of 60 days for conduct of special audit - no extension has been given by AO but by the Commissioner and the AO has only conveyed the approval, therefore, we hold that the grant of extension by the Commissioner is beyond the powers enshrined under the statute. Accordingly, the assessment completed after the due date is held to be void-ab-initio - AT
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