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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Eligibility under the DTVSV Scheme - appeals against the orders passed u/s 143(1)(a)(i) or (ii) as a separate category from the appeals from Clauses (iii) to (vi) of 143(1)(a) - When the circulars are issued exercising powers under sections 10 and 11 of DTVSV Act, directions are supposed to aid and smoothen bringing into operation provisions and execution of the actions based thereon. The directions, circulars would not be issued under such provisions digressing or deviating from the object and purpose under the scheme of the enactment. - HC
Eligibility under the DTVSV Scheme - appeals against the orders passed u/s 143(1)(a)(i) or (ii) as a separate category from the appeals from Clauses (iii) to (vi) of 143(1)(a) - When the circulars are issued exercising powers under sections 10 and 11 of DTVSV Act, directions are supposed to aid and smoothen bringing into operation provisions and execution of the actions based thereon. The directions, circulars would not be issued under such provisions digressing or deviating from the object and purpose under the scheme of the enactment. - HC
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