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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Special audit u/s 142(2A) - Period of limitation - reasons for change in accounting system - method of valuation of closing stock - AO does not point out a single complexity in the accounts of the assessee. - What is clearly evident is that the reference for special audit was merely made for obtaining certain explanation and information which were further required by the AO for the purposes of assessment of income of the assessee. In effect,the AO, was shifting his responsibility to the special auditor. This is surely not the purpose for which special audit can be referred to under law. - AT
Special audit u/s 142(2A) - Period of limitation - reasons for change in accounting system - method of valuation of closing stock - AO does not point out a single complexity in the accounts of the assessee. - What is clearly evident is that the reference for special audit was merely made for obtaining certain explanation and information which were further required by the AO for the purposes of assessment of income of the assessee. In effect,the AO, was shifting his responsibility to the special auditor. This is surely not the purpose for which special audit can be referred to under law. - AT
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