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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Addition u/s 68 - It is a simple case of switch over of investments from one company to another and is not the case of fresh loan received during the year. We thus find no substance in the ground that since the assessee has agitated the addition qua the share capital and share premium shown to have been received by it during assessment year 2008-09 by filing an appeal the assessee cannot claim the availability of such fund for making the investments. - No additions - AT
Addition u/s 68 - It is a simple case of switch over of investments from one company to another and is not the case of fresh loan received during the year. We thus find no substance in the ground that since the assessee has agitated the addition qua the share capital and share premium shown to have been received by it during assessment year 2008-09 by filing an appeal the assessee cannot claim the availability of such fund for making the investments. - No additions - AT
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