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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Rejection of turnover appearing in the books of accounts - It is already well-settled that in the absence of any definite adverse material accounts kept in regular course of business cannot be disbelieved and must be given credence and due weight - In the case in hand, no adverse material whatsoever was brought on record to disbelieve the account books maintained by the revisionist and therefore rejection of account books and enhancement of turnover is uncalled for.- HC
Rejection of turnover appearing in the books of accounts - It is already well-settled that in the absence of any definite adverse material accounts kept in regular course of business cannot be disbelieved and must be given credence and due weight - In the case in hand, no adverse material whatsoever was brought on record to disbelieve the account books maintained by the revisionist and therefore rejection of account books and enhancement of turnover is uncalled for.- HC
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