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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Undisclosed unaccounted expenditure and undisclosed income - By the connotation of "right person", it is meant the person who is liable to be taxed, according to law, with respect to a particular income. And that the expression "wrong person" is obviously used as an antithesis of the expression "right person" only. - We observe that this assessee is the "managing director" in the company. - And that it is this latter entity which the fact is engaged in all the business activity(ies) and has been assessed separately throughout. A company is very a body corporate and a distinct entity apart from its director. - CIT(A) has rightly deleted these twin additions in the assessee/individual's hands - AT
Undisclosed unaccounted expenditure and undisclosed income - By the connotation of "right person", it is meant the person who is liable to be taxed, according to law, with respect to a particular income. And that the expression "wrong person" is obviously used as an antithesis of the expression "right person" only. - We observe that this assessee is the "managing director" in the company. - And that it is this latter entity which the fact is engaged in all the business activity(ies) and has been assessed separately throughout. A company is very a body corporate and a distinct entity apart from its director. - CIT(A) has rightly deleted these twin additions in the assessee/individual's hands - AT
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