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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Addition u/s 68 - If the assessee could not produce the Directors during the assessment proceedings in response to the summons issued by the Assessing Officer due to lack of time, then what prevented the Assessing Officer to ask the assessee to produce the Directors during the course of remand report when ample opportunity was given by the CIT (A) to him. - Thus onus cast upon the assessee was duly discharged - AT
Addition u/s 68 - If the assessee could not produce the Directors during the assessment proceedings in response to the summons issued by the Assessing Officer due to lack of time, then what prevented the Assessing Officer to ask the assessee to produce the Directors during the course of remand report when ample opportunity was given by the CIT (A) to him. - Thus onus cast upon the assessee was duly discharged - AT
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