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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Unexplained investment OR STCG - Investment in land from undisclosed sources made in purchase of land from various persons/farmers - Suspected short term capital gain from sale of property - search u/s 132 - transfer of the land to the company under POA u/s 2(47) - The tax authorities are entitled to look into the surrounding circumstances are discussed hereinafter. Moreover, the question is that what was the need to prepare these documents by the company when no transactions have been made with the assessee - CIT(A) wrongly deleted the additions - AT
Unexplained investment OR STCG - Investment in land from undisclosed sources made in purchase of land from various persons/farmers - Suspected short term capital gain from sale of property - search u/s 132 - transfer of the land to the company under POA u/s 2(47) - The tax authorities are entitled to look into the surrounding circumstances are discussed hereinafter. Moreover, the question is that what was the need to prepare these documents by the company when no transactions have been made with the assessee - CIT(A) wrongly deleted the additions - AT
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