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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Validity of Settlement Commission order u/s 245D(4) - Proof of true and full disclosure of income - While this Court does not accept the contention of the petitioner regarding the Settlement Commission not being empowered to make assessment, it accepts the second submission of learned counsel for the petitioner that the Settlement Commission ought to have examined the matter after giving opportunity of hearing to the petitioner with regard to the true and correct disclosure - HC
Validity of Settlement Commission order u/s 245D(4) - Proof of true and full disclosure of income - While this Court does not accept the contention of the petitioner regarding the Settlement Commission not being empowered to make assessment, it accepts the second submission of learned counsel for the petitioner that the Settlement Commission ought to have examined the matter after giving opportunity of hearing to the petitioner with regard to the true and correct disclosure - HC
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