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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Disallowance of Professional Fees - The claim of the appellant rest on the ground that both the employees worked on retainer-ship basis and were qualified professional. The appointment of both the employees was purely a commercial decision keeping in mind the benefit of the business as a whole as it would be very important that the family persons should be employed in the own family business to control the management, operations, staff etc. so that there should not be any difficulty in running the business. The lower authorities, without questioning the appointment letter of both the persons, questioned the genuineness of the transaction. - AT
Disallowance of Professional Fees - The claim of the appellant rest on the ground that both the employees worked on retainer-ship basis and were qualified professional. The appointment of both the employees was purely a commercial decision keeping in mind the benefit of the business as a whole as it would be very important that the family persons should be employed in the own family business to control the management, operations, staff etc. so that there should not be any difficulty in running the business. The lower authorities, without questioning the appointment letter of both the persons, questioned the genuineness of the transaction. - AT
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