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 investment - Addition u/s 69/69B - An agreement even itself will not be enforceable in the eyes of law unless character of the land is changed viz. it is being converted into new tenure and such conversion is depended upon the payment of premium to the Government, and sanction from the Government. In these situations, it is difficult to infer that the assessee would pay on-money before such incident of conversion happen. This was the positive evidence produced by the assessees for rebutting the belief formed by the AO - CIT(A) rightly deleted the additions - AT
Unexplained investment - Addition u/s 69/69B - An agreement even itself will not be enforceable in the eyes of law unless character of the land is changed viz. it is being converted into new tenure and such conversion is depended upon the payment of premium to the Government, and sanction from the Government. In these situations, it is difficult to infer that the assessee would pay on-money before such incident of conversion happen. This was the positive evidence produced by the assessees for rebutting the belief formed by the AO - CIT(A) rightly deleted the additions - AT
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