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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Validity of selection of case for scrutiny under compulsory scrutiny criteria - the assessee has challenged the scrutiny assessment as the Assessing Officer has not obtained necessary sanction from the competent authority as per the instruction of CBDT - when the fact of the conducting the survey as well as the post survey enquiry is not in dispute then the case of the assessee would certainly fall under the category of selection under compulsory scrutiny. No substance or merit in the additional ground raised by the assessee - AT
Validity of selection of case for scrutiny under compulsory scrutiny criteria - the assessee has challenged the scrutiny assessment as the Assessing Officer has not obtained necessary sanction from the competent authority as per the instruction of CBDT - when the fact of the conducting the survey as well as the post survey enquiry is not in dispute then the case of the assessee would certainly fall under the category of selection under compulsory scrutiny. No substance or merit in the additional ground raised by the assessee - AT
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