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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Levy of penalty u/s 271(1)(c) - Filing of revised return offering an additions sum after initiating enquiry proceedings after the expiry of permissible period - Once we have found that the revised return cannot have the effect of effacing the original return, it is explicit that concealment of the particulars of income and furnishing of inaccurate particulars of income were revealed to the assessing officer in the course of proceedings under the Act - Levy of penalty confirmed - HC
Levy of penalty u/s 271(1)(c) - Filing of revised return offering an additions sum after initiating enquiry proceedings after the expiry of permissible period - Once we have found that the revised return cannot have the effect of effacing the original return, it is explicit that concealment of the particulars of income and furnishing of inaccurate particulars of income were revealed to the assessing officer in the course of proceedings under the Act - Levy of penalty confirmed - HC
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