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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Renting of immovable property service - receipt of onetime non-refundable contribution - The entire case of the department is that one time refundable amount collected by the appellant from its member units is the service charge against the provision of ‘Renting of Immovable Property Service’ but the department has not adduced a single evidence in support of its allegation. Hence, the contribution of the department in this regard has no legs to stand - AT
Renting of immovable property service - receipt of onetime non-refundable contribution - The entire case of the department is that one time refundable amount collected by the appellant from its member units is the service charge against the provision of ‘Renting of Immovable Property Service’ but the department has not adduced a single evidence in support of its allegation. Hence, the contribution of the department in this regard has no legs to stand - AT
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