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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Bad debts - Disallowance of deduction claimed in respect of notional interest taxed as income in earlier year, which was not realized by the appellant - the assessee is not in money lending, therefore, the assessee cannot claim that the assessee made inter corporate deposit in the course of his business. During the earlier years the assessee never claimed as a business loss on account of non-receipt of interest on such inter corporate deposit, therefore, the assessee is also not entitled for business loss as well. - AT
Bad debts - Disallowance of deduction claimed in respect of notional interest taxed as income in earlier year, which was not realized by the appellant - the assessee is not in money lending, therefore, the assessee cannot claim that the assessee made inter corporate deposit in the course of his business. During the earlier years the assessee never claimed as a business loss on account of non-receipt of interest on such inter corporate deposit, therefore, the assessee is also not entitled for business loss as well. - AT
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