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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Unexplained expenditures and unaccounted cash payment - Onus to proof - once the revenue has treated the entire amount of expenditure as unexplained expense under section 69C of the Act, there cannot be any addition separately being part and parcel of the total addition otherwise it would lead to the double addition which is not warranted under the provisions of law until and unless the provisions of law requires so - AT
Unexplained expenditures and unaccounted cash payment - Onus to proof - once the revenue has treated the entire amount of expenditure as unexplained expense under section 69C of the Act, there cannot be any addition separately being part and parcel of the total addition otherwise it would lead to the double addition which is not warranted under the provisions of law until and unless the provisions of law requires so - AT
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