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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Addition applying the provisions of section 50C - Once the assessee has raised the objection against the adoption of deemed full value consideration in terms of section 50C of the Income Tax Act, the Assessing Officer is duty bound to refer the matter to the DDO for determination of the fair market value of the property in terms of section 50C(2) of the Income Tax Act. Since, the Assessing Officer has not taken any step to determine the fair market value, matter restored back - AT
Addition applying the provisions of section 50C - Once the assessee has raised the objection against the adoption of deemed full value consideration in terms of section 50C of the Income Tax Act, the Assessing Officer is duty bound to refer the matter to the DDO for determination of the fair market value of the property in terms of section 50C(2) of the Income Tax Act. Since, the Assessing Officer has not taken any step to determine the fair market value, matter restored back - AT
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