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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Deduction u/s 80IAB - development of SEZ - BOA has granted approval to the assessee. This approval has not been cancelled or suspended. It was valid. The assessee has offered a piece of land at lease rent for a period of 99 years with development charges - The receipt has been shown as income - Sister concern has already applied to the BOA Before the 31st March for approval. - It could not be doubted by referring an aspect that capital expenditure shown and capitalized under the head work-in-progress was bogus. On the basis of such an observation, deduction otherwise admissible to the assessee cannot be denied. - AT
Deduction u/s 80IAB - development of SEZ - BOA has granted approval to the assessee. This approval has not been cancelled or suspended. It was valid. The assessee has offered a piece of land at lease rent for a period of 99 years with development charges - The receipt has been shown as income - Sister concern has already applied to the BOA Before the 31st March for approval. - It could not be doubted by referring an aspect that capital expenditure shown and capitalized under the head work-in-progress was bogus. On the basis of such an observation, deduction otherwise admissible to the assessee cannot be denied. - AT
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