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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Penalty u/s. 271(1)(b) - in spite of the various adjournments given by the AO to assessee, no return of income was filed by the assessee in spite of the various opportunities given by the AO to the Authorised Representative of the assessee and lastly the AR of the assessee shows his inability and therefore, the AO has rightly imposed the penalty in dispute - AT
Penalty u/s. 271(1)(b) - in spite of the various adjournments given by the AO to assessee, no return of income was filed by the assessee in spite of the various opportunities given by the AO to the Authorised Representative of the assessee and lastly the AR of the assessee shows his inability and therefore, the AO has rightly imposed the penalty in dispute - AT
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