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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Reopening of assessment u/s 147 - In the case on hand, upon disclosure made by the assessee with regard to the date for put to use of the assets, the Assessing Officer thought fit not to disallow the depreciation claimed by the assessee. Therefore, when primary materials having been disclosed bonafide, a mere technical mistake committed by the auditor, could not be said to be an “omission” or “failure” to disclose fully and truly all material facts for the assessment by the assessee. - HC
Reopening of assessment u/s 147 - In the case on hand, upon disclosure made by the assessee with regard to the date for put to use of the assets, the Assessing Officer thought fit not to disallow the depreciation claimed by the assessee. Therefore, when primary materials having been disclosed bonafide, a mere technical mistake committed by the auditor, could not be said to be an “omission” or “failure” to disclose fully and truly all material facts for the assessment by the assessee. - HC
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