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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Clandestine removal - shortage of goods detected on stock taking - MS Ingots - Admissions are the best evidence and need no further proof as is the established principle of Indian Evidence Act in Section 58 thereof. Hence the argument of the appellant that the department has not produced any evidence is not sustainable in the eyes of the admission of the appellant’s Director for the noticed shortage and for simultaneous non compliance of Rule 10 thereof. - AT
Clandestine removal - shortage of goods detected on stock taking - MS Ingots - Admissions are the best evidence and need no further proof as is the established principle of Indian Evidence Act in Section 58 thereof. Hence the argument of the appellant that the department has not produced any evidence is not sustainable in the eyes of the admission of the appellant’s Director for the noticed shortage and for simultaneous non compliance of Rule 10 thereof. - AT
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