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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Estimation of income - Accommodation entry provider - the only material with the Revenue authorities is that of the statement of entry operators confirming that they have received brokerage/commission at the rate of 0.25% to 0.5% from the assessee, which fact has not been doubted by the authorities. Though the ld.CIT(A) has to some extent justified to restrict the impugned disallowance, but he has not given due weightage to the only evidence available on record in form of statement of entry operators has not been considered logically. - AT
Estimation of income - Accommodation entry provider - the only material with the Revenue authorities is that of the statement of entry operators confirming that they have received brokerage/commission at the rate of 0.25% to 0.5% from the assessee, which fact has not been doubted by the authorities. Though the ld.CIT(A) has to some extent justified to restrict the impugned disallowance, but he has not given due weightage to the only evidence available on record in form of statement of entry operators has not been considered logically. - AT
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