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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Rectification u/s 154 - Transfer pricing adjustments - The assessee carried the matter on appeal to the Tribunal and once again, the assessee never raised any contention with regard to the validity of the notice dated 28.03.2006. Thus, considering this factual situation, we are of the clear view that the present attempt of the assessee is not tenable and accordingly rejected. - The assessment order dated 28.02.2006 is an order u/s 143(3) and not an order u/s 92C(3) of the Act. - The argument of the assessee before us is that the Assessing Officer has exercised jurisdiction u/s 92C(3) and the TPO parallely cannot exercise his power u/s92CA. On facts, the assessee is wrong. - HC
Rectification u/s 154 - Transfer pricing adjustments - The assessee carried the matter on appeal to the Tribunal and once again, the assessee never raised any contention with regard to the validity of the notice dated 28.03.2006. Thus, considering this factual situation, we are of the clear view that the present attempt of the assessee is not tenable and accordingly rejected. - The assessment order dated 28.02.2006 is an order u/s 143(3) and not an order u/s 92C(3) of the Act. - The argument of the assessee before us is that the Assessing Officer has exercised jurisdiction u/s 92C(3) and the TPO parallely cannot exercise his power u/s92CA. On facts, the assessee is wrong. - HC
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