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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Assessment u/s 153C - Period of limitation - although the Assessing Officer of the searched person and the other person(the assessee) was the same, satisfaction was recorded by the Assessing Officer for invoking the provisions of section 153C of the Act on 21/12/2010, the said date would be deemed to be the date of receiving documents by the Assessing Officer. Thus, the year of search would be FY 2010-11 relevant to AY 2011-12. - AT
Assessment u/s 153C - Period of limitation - although the Assessing Officer of the searched person and the other person(the assessee) was the same, satisfaction was recorded by the Assessing Officer for invoking the provisions of section 153C of the Act on 21/12/2010, the said date would be deemed to be the date of receiving documents by the Assessing Officer. Thus, the year of search would be FY 2010-11 relevant to AY 2011-12. - AT
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