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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Nature of loss - capital loss or trading loss - Material (silver) loan taken by assessee - At time of return of Material, price has gone high and resulted in loss - n the present case the assessee was able to carry on its business activities with the assistance of the material loan without which it was not possible for it to carry on the business. - the assessee is eligible for deduction under the provisions of section 37/28 of the Act as the case may be. - AT
Nature of loss - capital loss or trading loss - Material (silver) loan taken by assessee - At time of return of Material, price has gone high and resulted in loss - n the present case the assessee was able to carry on its business activities with the assistance of the material loan without which it was not possible for it to carry on the business. - the assessee is eligible for deduction under the provisions of section 37/28 of the Act as the case may be. - AT
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