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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Best judgement assessment - formulae for levying the purchase tax on the ground that separate accounts are absent - There was absolutely no necessity or need for making any guess work. If the records are not available, then, the authority will have to take recourse to such best judgment assessment exercise. Instead of calling upon the petitioner to make available the records, the respondent had fallen back on guess work. On this sole ground, the impugned orders are quashed - HC
Best judgement assessment - formulae for levying the purchase tax on the ground that separate accounts are absent - There was absolutely no necessity or need for making any guess work. If the records are not available, then, the authority will have to take recourse to such best judgment assessment exercise. Instead of calling upon the petitioner to make available the records, the respondent had fallen back on guess work. On this sole ground, the impugned orders are quashed - HC
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