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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Denial of interest on refund claim - There is no infirmity in the Order under challenge where interest has not been awarded while sanctioning refund - Bare perusal of section 27 makes it clear that interest has to be given by the department while sanctioning the refund only when the sanction order has been passed after period beyond three months of seeking refund. - AT
Denial of interest on refund claim - There is no infirmity in the Order under challenge where interest has not been awarded while sanctioning refund - Bare perusal of section 27 makes it clear that interest has to be given by the department while sanctioning the refund only when the sanction order has been passed after period beyond three months of seeking refund. - AT
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