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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Reopening of assessment u/s 147 - Disallowing claim of weighted deduction of 175% under section 35(l)(ii) on the ground that donation receipt is not submitted - Allegation of providing accommodation entries - upon reopening on the basis of the same information the Assessing Officer made the assessment disallowing the payment. There is no further material brought on record by the Assessing Officer. The assessee has submitted the payment evidence. The same was through banking channel. - Claim cannot be denied - AT
Reopening of assessment u/s 147 - Disallowing claim of weighted deduction of 175% under section 35(l)(ii) on the ground that donation receipt is not submitted - Allegation of providing accommodation entries - upon reopening on the basis of the same information the Assessing Officer made the assessment disallowing the payment. There is no further material brought on record by the Assessing Officer. The assessee has submitted the payment evidence. The same was through banking channel. - Claim cannot be denied - AT
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