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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Deduction u/s 80IC - ‘initial assessment year’ - whether the initial Assessment Year can be re-fixed in case of substantial expansion? - Although, the Department has vehemently opposed the orders of the CIT(A) granting deduction @ 100%, we find no error either in law or on facts having been committed by Ld. CIT(A) in the two captioned appeals as the Ld. CIT(A) has only followed the interpretation as laid down by the Coordinate Bench of this Tribunal. - AT
Deduction u/s 80IC - ‘initial assessment year’ - whether the initial Assessment Year can be re-fixed in case of substantial expansion? - Although, the Department has vehemently opposed the orders of the CIT(A) granting deduction @ 100%, we find no error either in law or on facts having been committed by Ld. CIT(A) in the two captioned appeals as the Ld. CIT(A) has only followed the interpretation as laid down by the Coordinate Bench of this Tribunal. - AT
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