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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Valuation - disallowance of deduction from assessable value - deduction on interest on receivables and collection charges on the delay in payment for each invoice - In the remand proceedings, the Assistant Commissioner and the Commissioner (Appeals) were not required to examine whether the amount on ‘interest on receivables’ and ‘bank charges’ is inbuilt in the price, but yet they not only proceeded to examine it but recorded a finding against the appellant. - Further, when the earlier decision of tribunal on the same issue has attained finally, the contrary order cannot sustained - AT
Valuation - disallowance of deduction from assessable value - deduction on interest on receivables and collection charges on the delay in payment for each invoice - In the remand proceedings, the Assistant Commissioner and the Commissioner (Appeals) were not required to examine whether the amount on ‘interest on receivables’ and ‘bank charges’ is inbuilt in the price, but yet they not only proceeded to examine it but recorded a finding against the appellant. - Further, when the earlier decision of tribunal on the same issue has attained finally, the contrary order cannot sustained - AT
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