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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Disallowance u/s. 40A(3) - no disallowance can be made u/s. 40A(3) and benefit of rule 6DD(j) will be given to the assessee therein it is contemplated that if payment of Rs. More than ₹ 20,000/- paid in cash “where the payment was required to be made on a day on which banks were closed on account of holiday or strike.” It is pertinent to note here that assessee took this plea which was not accepted by the lower authorities so to our mind same is amounting to miscarriage of justice - AT
Disallowance u/s. 40A(3) - no disallowance can be made u/s. 40A(3) and benefit of rule 6DD(j) will be given to the assessee therein it is contemplated that if payment of Rs. More than ₹ 20,000/- paid in cash “where the payment was required to be made on a day on which banks were closed on account of holiday or strike.” It is pertinent to note here that assessee took this plea which was not accepted by the lower authorities so to our mind same is amounting to miscarriage of justice - AT
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