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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Refund of excess amount of Duty and interest paid - principles of unjust enrichment - The refund here, in this case, is claimed for a few years only and just by referring to one year’s Books of Account, it cannot be concluded that the expenditure having not been carried forward, the same is not considered as a receivable. In any case, nothing turns in so far as taxation is concerned on a mere accounting treatment. - AT
Refund of excess amount of Duty and interest paid - principles of unjust enrichment - The refund here, in this case, is claimed for a few years only and just by referring to one year’s Books of Account, it cannot be concluded that the expenditure having not been carried forward, the same is not considered as a receivable. In any case, nothing turns in so far as taxation is concerned on a mere accounting treatment. - AT
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