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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Assessment in search cases - Approval of JCIT u/s 153D - Period of limitation - JCIT has mentioned at the bottom of the approval that draft assessment order has been received late by him on 31.12.2016 beyond the time limit as per internal action plan and thus having a very little period for proper examination of the facts of the case and further inquiries. The ld JCIT, Central Range, Meerut has mentioned such a fact on the letter of approval sent by the ld AO. - issue of approval is covered in favour of the assessee - AT
Assessment in search cases - Approval of JCIT u/s 153D - Period of limitation - JCIT has mentioned at the bottom of the approval that draft assessment order has been received late by him on 31.12.2016 beyond the time limit as per internal action plan and thus having a very little period for proper examination of the facts of the case and further inquiries. The ld JCIT, Central Range, Meerut has mentioned such a fact on the letter of approval sent by the ld AO. - issue of approval is covered in favour of the assessee - AT
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