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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TDS u/s 194IA - payment for land advance - non-deduction of TDS in violation of Section 40(a)(ia) - the provisions of Section 40(a)(ia) are applicable only to the expenditure claimed while computing income under the head “profit and gains of business or profession” of the Income Tax Act, 1961. In this case, this amount has not been claimed as expenditure being the amount paid as advance for acquisition of a capital asset. - No additions could be made - AT
TDS u/s 194IA - payment for land advance - non-deduction of TDS in violation of Section 40(a)(ia) - the provisions of Section 40(a)(ia) are applicable only to the expenditure claimed while computing income under the head “profit and gains of business or profession” of the Income Tax Act, 1961. In this case, this amount has not been claimed as expenditure being the amount paid as advance for acquisition of a capital asset. - No additions could be made - AT
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