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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Gift received from relatives - unexplained cash credit u/s 69 - Tribunal found that the assessee had not made out grounds to permit to bring in such additional evidence on record. To bring additional evidence on record at the stage before the Tribunal, the concerned party would have to demonstrate the reasons why the same could not be done earlier. The Tribunal found no justification in this respect. Entire issue is thus based on facts - HC
Gift received from relatives - unexplained cash credit u/s 69 - Tribunal found that the assessee had not made out grounds to permit to bring in such additional evidence on record. To bring additional evidence on record at the stage before the Tribunal, the concerned party would have to demonstrate the reasons why the same could not be done earlier. The Tribunal found no justification in this respect. Entire issue is thus based on facts - HC
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