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 peak cash loan - interest expenses on the money borrowed in cash - it is a fact on record that the impugned amount of interest as well as the amount of loan computed by the AO based on such interest, was not recorded in the regular books of accounts. Therefore, in our considered view the impugned amount of loan not recorded in the regular books of accounts cannot attract the provisions of section 68 of the Act. - AT
Unexplained peak cash loan - interest expenses on the money borrowed in cash - it is a fact on record that the impugned amount of interest as well as the amount of loan computed by the AO based on such interest, was not recorded in the regular books of accounts. Therefore, in our considered view the impugned amount of loan not recorded in the regular books of accounts cannot attract the provisions of section 68 of the Act. - AT
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