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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Seeking withdrawal of best judgment assessment orders passed - return filed within (granted extended) time or not - If that were to be so, though the period of 30 days as provided under Section 62 (2) in the peculiar facts of the case, in light of permission granted by the court in its order dated 13.02.2019, the petitioner could continue to file the return within the time granted by the Court and the return filed was a return as contemplated under Section 62 (2) which is to be construed to be return filed within the time. - HC
Seeking withdrawal of best judgment assessment orders passed - return filed within (granted extended) time or not - If that were to be so, though the period of 30 days as provided under Section 62 (2) in the peculiar facts of the case, in light of permission granted by the court in its order dated 13.02.2019, the petitioner could continue to file the return within the time granted by the Court and the return filed was a return as contemplated under Section 62 (2) which is to be construed to be return filed within the time. - HC
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