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 towards office rent and office maintenance charges - apportionment of expenses to the sister concerns and group companies - When all the assessee's sister companies are only paper companies with no activities conducted during the relevant assessment year it is obvious that the entire expenses incurred towards office rent and office maintenance charges are attributable to the assessee company and therefore these expenses cannot be apportioned to the assessee's sister companies and if at all apportionable it would be negligible. - AT
Addition towards office rent and office maintenance charges - apportionment of expenses to the sister concerns and group companies - When all the assessee's sister companies are only paper companies with no activities conducted during the relevant assessment year it is obvious that the entire expenses incurred towards office rent and office maintenance charges are attributable to the assessee company and therefore these expenses cannot be apportioned to the assessee's sister companies and if at all apportionable it would be negligible. - AT
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