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 u/s 68 - Addition on the basis of income shown in Form No. 26AS - Mercantile system of accounting - There can be overflow of income of one preceding previous year in the current year in form 26AS. However, there cannot be overflow of income pertaining to the preceding previous year in the current previous year in the books of accounts of the assessee because assessee is maintaining books of accounts on accrual system of accounting. AO should have considered the income shown by the assessee in the earlier year in its profit and loss account, when assessee has filed detailed reconciliation before the ld AO. - AT
Addition u/s 68 - Addition on the basis of income shown in Form No. 26AS - Mercantile system of accounting - There can be overflow of income of one preceding previous year in the current year in form 26AS. However, there cannot be overflow of income pertaining to the preceding previous year in the current previous year in the books of accounts of the assessee because assessee is maintaining books of accounts on accrual system of accounting. AO should have considered the income shown by the assessee in the earlier year in its profit and loss account, when assessee has filed detailed reconciliation before the ld AO. - AT
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