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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Exemption u/s.10(23) denied - anonymous donations received by any assessee or entity u/s.115BBC - without verifying the documents and objectively selecting some entries and leaving aside the other entries and documentary evidence even without verifying the actual receipt of donation from the so-called donors, if the revenue authorities proceeds to make any addition treating the same as anonymous u/s.115BBC of the Act, then have no hesitation to hold that the addition made is without any basis and keeping aside the sound principles of tax jurisprudence, the same cannot be held as sustainable - AT
Exemption u/s.10(23) denied - anonymous donations received by any assessee or entity u/s.115BBC - without verifying the documents and objectively selecting some entries and leaving aside the other entries and documentary evidence even without verifying the actual receipt of donation from the so-called donors, if the revenue authorities proceeds to make any addition treating the same as anonymous u/s.115BBC of the Act, then have no hesitation to hold that the addition made is without any basis and keeping aside the sound principles of tax jurisprudence, the same cannot be held as sustainable - AT
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