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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Exemption u/s 11 - charitable activity u/s 2(15) - cancellation of registration u/s 12AA - the assessee submitted that the same were directly deposited in the in the bank account and duly accounted in the books of accounts. If the Ld.CIT(E) suspects the donations, the CIT(E) ought to have taken action for assessing the same as income u/s 68 r.w.s. 115BBE as per law, but there is no case for suspecting the genuineness of the activity of the society. - AT
Exemption u/s 11 - charitable activity u/s 2(15) - cancellation of registration u/s 12AA - the assessee submitted that the same were directly deposited in the in the bank account and duly accounted in the books of accounts. If the Ld.CIT(E) suspects the donations, the CIT(E) ought to have taken action for assessing the same as income u/s 68 r.w.s. 115BBE as per law, but there is no case for suspecting the genuineness of the activity of the society. - AT
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