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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MAT computation u/s 115JB - In this case, the assessee had incurred business loss / depreciation losses as per books in the AYs 1999-00 & 2000-01 & AYs 2011-12 & 2012-13 alone, which were completely set off (ie both the losses viz unabsorbed business and unabsorbed depreciation losses were set off) , from the book profits of the remaining assessment years till the previous assessment year 2013-14 and the book profit as per the profit and Loss account balance as on 01.04.2013 per the balance sheet in the books of account - Thus, on the above facts, in effect there remains no brought forward business loss / unabsorbed depreciation loss available as per books for setting off against the book profit of this assessment year. - AT
MAT computation u/s 115JB - In this case, the assessee had incurred business loss / depreciation losses as per books in the AYs 1999-00 & 2000-01 & AYs 2011-12 & 2012-13 alone, which were completely set off (ie both the losses viz unabsorbed business and unabsorbed depreciation losses were set off) , from the book profits of the remaining assessment years till the previous assessment year 2013-14 and the book profit as per the profit and Loss account balance as on 01.04.2013 per the balance sheet in the books of account - Thus, on the above facts, in effect there remains no brought forward business loss / unabsorbed depreciation loss available as per books for setting off against the book profit of this assessment year. - AT
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