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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Addition u/s 68 - unsecured loan - Very fairly, the learned Senior counsel has submitted that, specifically that chance of personal hearing, though was not asked by the petitioner/Assessee, that become incumbent on the part of the petitioner/Assessee to seek such a chance of personal hearing, in view of the peculiar facts of the case, where, the petitioner has been placed to explain with the documents already submitted to the revenue people to establish that the transactions under which, the petitioner/Assessee accepted that sum from a lender was a genuine transaction taken through the bank. - such a chance can be given to the petitioner/Assessee - Matter restored back - HC
Addition u/s 68 - unsecured loan - Very fairly, the learned Senior counsel has submitted that, specifically that chance of personal hearing, though was not asked by the petitioner/Assessee, that become incumbent on the part of the petitioner/Assessee to seek such a chance of personal hearing, in view of the peculiar facts of the case, where, the petitioner has been placed to explain with the documents already submitted to the revenue people to establish that the transactions under which, the petitioner/Assessee accepted that sum from a lender was a genuine transaction taken through the bank. - such a chance can be given to the petitioner/Assessee - Matter restored back - HC
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