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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Deduction u/s 36(1)(viii) - Whether assessee is eligible for deduction u/s 36(1)(viii) even though the assessee is not an eligible entity under the provisions of the Act prior to amendment w.e.f. 01.04.2008? - the assessee is squarely covered within the meaning of expression ‘Financial Corporation’ and is entitled to benefit of deduction under Section 36(1)(viii) of the Act. - HC
Deduction u/s 36(1)(viii) - Whether assessee is eligible for deduction u/s 36(1)(viii) even though the assessee is not an eligible entity under the provisions of the Act prior to amendment w.e.f. 01.04.2008? - the assessee is squarely covered within the meaning of expression ‘Financial Corporation’ and is entitled to benefit of deduction under Section 36(1)(viii) of the Act. - HC
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