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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Unaccounted sales of car parking area - Nothing came into the notice that there is any change or variation in the order passed by the Ld.CIT(A) for the AY 2012-13. in which the claim of the assessee regarding sale of parking was allowed to the extent of 99%. Needless to say that in the present assessment year, the claim of 1% is only in question. The facts are not distinguishable at this stage. - AT
Unaccounted sales of car parking area - Nothing came into the notice that there is any change or variation in the order passed by the Ld.CIT(A) for the AY 2012-13. in which the claim of the assessee regarding sale of parking was allowed to the extent of 99%. Needless to say that in the present assessment year, the claim of 1% is only in question. The facts are not distinguishable at this stage. - AT
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