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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Levy of interest u/s 234B and 234C - Liability of advance tax - income from partnership firm in the hands of partner - As per the provisions of Sec. 10(2A) of the Act, the share of profit of the partnership firm is exempted in the hands of the partner. - both the provisions u/Sec 207 & Sec 208 are not inclusive and are independently applicable. The assessee case falls within the purview of provisions of section 207(2) of the Act which cannot be disputed. - Interest liability to be deleted - AT
Levy of interest u/s 234B and 234C - Liability of advance tax - income from partnership firm in the hands of partner - As per the provisions of Sec. 10(2A) of the Act, the share of profit of the partnership firm is exempted in the hands of the partner. - both the provisions u/Sec 207 & Sec 208 are not inclusive and are independently applicable. The assessee case falls within the purview of provisions of section 207(2) of the Act which cannot be disputed. - Interest liability to be deleted - AT
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