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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Valuation of closing stock - Because the assessee is playing this direction/clarification in order to get the matter stated under the Vivad-se-Vishwas Scheme, in the absence of any dispute as to the principle involved in this, we are of the considered opinion that there is no harm in issuing such clarification and we accordingly direct the authorities to treat the closing stock of the assessment year 2013-14 as the opening stock for the assessment year 2014-15. - AT
Valuation of closing stock - Because the assessee is playing this direction/clarification in order to get the matter stated under the Vivad-se-Vishwas Scheme, in the absence of any dispute as to the principle involved in this, we are of the considered opinion that there is no harm in issuing such clarification and we accordingly direct the authorities to treat the closing stock of the assessment year 2013-14 as the opening stock for the assessment year 2014-15. - AT
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