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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Taxability of write back of 'Non-Plan Government Loans' claiming the same to be capital receipts not chargeable to income-tax - it could not be said that the assessee has not obtained or derived benefit from the waiver - assessee is definitely hit by provisions of Section 28(iv) and 41(1) of the 1961 Act - we do not find fault with the assessment order passed by the AO that merely because relevant provision of the 1961 statute is not mentioned in assessment order, will take otherwise taxable receipt out of taxation purview merely on the ground that relevant Section is not mentioned by the AO. - AT
Taxability of write back of 'Non-Plan Government Loans' claiming the same to be capital receipts not chargeable to income-tax - it could not be said that the assessee has not obtained or derived benefit from the waiver - assessee is definitely hit by provisions of Section 28(iv) and 41(1) of the 1961 Act - we do not find fault with the assessment order passed by the AO that merely because relevant provision of the 1961 statute is not mentioned in assessment order, will take otherwise taxable receipt out of taxation purview merely on the ground that relevant Section is not mentioned by the AO. - AT
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