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. 80IB(11A) - When the statue in section 80 IB of the Act has not made any distinct between export and domestic sales and the profit arising from both the kind of sales is entitled for deduction, then, the profit earned by the assessee in the form of DEPB entitlement amount, which is directly related and calculated on the amount of export sales, cannot be regarded or tagged as income from other sources to take it out from the benefit of deduction u/s. 80IB(11A) - AT
Deduction u/s. 80IB(11A) - When the statue in section 80 IB of the Act has not made any distinct between export and domestic sales and the profit arising from both the kind of sales is entitled for deduction, then, the profit earned by the assessee in the form of DEPB entitlement amount, which is directly related and calculated on the amount of export sales, cannot be regarded or tagged as income from other sources to take it out from the benefit of deduction u/s. 80IB(11A) - AT
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