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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Bogus sundry creditors - Assessee has provided details of the creditors, which should have been examined by both the authorities below but they did not do so for proving the genuineness of the creditors. As per our considered opinion, the assessee discharged his liability as cast upon him and now the duty shifted on the revenue authorities for the verification of the genuineness of the creditors, which are lack in this case. - AT
Bogus sundry creditors - Assessee has provided details of the creditors, which should have been examined by both the authorities below but they did not do so for proving the genuineness of the creditors. As per our considered opinion, the assessee discharged his liability as cast upon him and now the duty shifted on the revenue authorities for the verification of the genuineness of the creditors, which are lack in this case. - AT
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