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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Penalty order u/s 271AAA - disclosure of additions income pursuant to search u/s 132 - In the present case the assessee has disclosed the entire source of income and manner of undisclosed income earned - assessee has also paid the taxes and the details - The assessee has admitted the undisclosed income and voluntarily declared the same under section 132 (4) of the Act on the basis of accounting records consisting of its income from all the sources. It means that the assessee has complied with all the conditions mentioned in section 271AAA(2) - No penalty - AT
Penalty order u/s 271AAA - disclosure of additions income pursuant to search u/s 132 - In the present case the assessee has disclosed the entire source of income and manner of undisclosed income earned - assessee has also paid the taxes and the details - The assessee has admitted the undisclosed income and voluntarily declared the same under section 132 (4) of the Act on the basis of accounting records consisting of its income from all the sources. It means that the assessee has complied with all the conditions mentioned in section 271AAA(2) - No penalty - AT
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