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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Exemption u/s 11 - Rejection of application u/s 12A - at the time of grant of registration to assessee the ld. CIT(E) has to examine the objects of the assessee as well as the genuineness of activities of the assessee. Therefore in view of these facts and circumstances we deem it appropriate to remit the matter back to ld. CIT(E) who should pass a fresh order in accordance with the provisions of law and after providing sufficient opportunity to the assessee of being heard. Appeal of the assessee is allowed for statistical purposes. - AT
Exemption u/s 11 - Rejection of application u/s 12A - at the time of grant of registration to assessee the ld. CIT(E) has to examine the objects of the assessee as well as the genuineness of activities of the assessee. Therefore in view of these facts and circumstances we deem it appropriate to remit the matter back to ld. CIT(E) who should pass a fresh order in accordance with the provisions of law and after providing sufficient opportunity to the assessee of being heard. Appeal of the assessee is allowed for statistical purposes. - AT
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