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 books of accounts - valuation of the closing stock - gross profit margin - Assessment was complete u/s 143(3) - After that, during survey u/s 133A, assessee could not produce stock register - with the assessment having been completed under Section 143 (3) of the IT Act, and after the Assessee had produced its books of account, the question of invoking Section 145 of the IT Act did not arise - ITAT committed a serious error. It proceeded on that basis to re-work the gross profit margin. - HC
Rejection of books of accounts - valuation of the closing stock - gross profit margin - Assessment was complete u/s 143(3) - After that, during survey u/s 133A, assessee could not produce stock register - with the assessment having been completed under Section 143 (3) of the IT Act, and after the Assessee had produced its books of account, the question of invoking Section 145 of the IT Act did not arise - ITAT committed a serious error. It proceeded on that basis to re-work the gross profit margin. - HC
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