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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Unaccounted cash receipt - Addition on the basis of scribbling pad found during the course of search - even though the employees statement were not retracted, the same cannot be considered as an evidence which can be used against the assessee when the Managing Director of the assessee company has retracted his statement along with sworn affidavit explaining the reasons. - AO directed to delete additions made towards undisclosed income on the basis of scribbling pad - AT
Unaccounted cash receipt - Addition on the basis of scribbling pad found during the course of search - even though the employees statement were not retracted, the same cannot be considered as an evidence which can be used against the assessee when the Managing Director of the assessee company has retracted his statement along with sworn affidavit explaining the reasons. - AO directed to delete additions made towards undisclosed income on the basis of scribbling pad - AT
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