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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Claim of deduction u/s 48(i) - deduction of expenditure incurred wholly and exclusively in connection with the transfer of shares - whether the expenditure is incurred wholly and exclusively in connection with transfer of an asset is a question of fact, which depends in the facts and circumstances of the case. - Assessee was unable to point out that three share holders who were parties to the same transaction had claimed the similar expenditure in their returns as was claimed by the assessee - HC
Claim of deduction u/s 48(i) - deduction of expenditure incurred wholly and exclusively in connection with the transfer of shares - whether the expenditure is incurred wholly and exclusively in connection with transfer of an asset is a question of fact, which depends in the facts and circumstances of the case. - Assessee was unable to point out that three share holders who were parties to the same transaction had claimed the similar expenditure in their returns as was claimed by the assessee - HC
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