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 of expenditure incurred in Cash under the head 'pond and farm maintenance' u/s. 40A(3) - as per the ledger account copy furnished by the assessee, all payments have been made to labours for cleaning of pond and JCB baffling charges. Therefore, we are of the considered view that expenditure debited under the head 'pond and farm maintenance expenses' cannot come under the exclusion provided under Rule 6DD(e) of IT Rules, 1962. - AT
Disallowance of expenditure incurred in Cash under the head 'pond and farm maintenance' u/s. 40A(3) - as per the ledger account copy furnished by the assessee, all payments have been made to labours for cleaning of pond and JCB baffling charges. Therefore, we are of the considered view that expenditure debited under the head 'pond and farm maintenance expenses' cannot come under the exclusion provided under Rule 6DD(e) of IT Rules, 1962. - AT
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