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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Unexplained share capital - share premium and share application money - Ld.CIT(A) has noted as assessee has filed the confirmation letters, copies of ITRs, copies of bank statements of five parties, who invested share capital. Besides, the assessee has filed the allotment letters, returns as filed with the AO along with Board’s resolution for allotment of shares - No addition could be made - AT
Unexplained share capital - share premium and share application money - Ld.CIT(A) has noted as assessee has filed the confirmation letters, copies of ITRs, copies of bank statements of five parties, who invested share capital. Besides, the assessee has filed the allotment letters, returns as filed with the AO along with Board’s resolution for allotment of shares - No addition could be made - AT
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