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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SVLDRS - Eligibility of the declarant for making a declaration under the category of ‘investigation, enquiry or audit’ - acknowledgment or admission by the petitioner was before the cut-off date of 30.06.2019. - Though the final audit report may be post 30.06.2019, the admission of the petitioner was certainly prior to 30.06.2019 - rejection of the declaration of the petitioner dated 02.12.2019 by the designated committee on 12.02.2020 is not justified. - HC
SVLDRS - Eligibility of the declarant for making a declaration under the category of ‘investigation, enquiry or audit’ - acknowledgment or admission by the petitioner was before the cut-off date of 30.06.2019. - Though the final audit report may be post 30.06.2019, the admission of the petitioner was certainly prior to 30.06.2019 - rejection of the declaration of the petitioner dated 02.12.2019 by the designated committee on 12.02.2020 is not justified. - HC
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