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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Valuation- inter-connected undertaking - related parties or not - applicability of doctrine of mutuality of interest - The fact that Appellant 1 and Appellant 2 were not related person has been brought out in the cost auditor report received by the department on 31.12.2007, as recorded while recording the submissions of the appellant in the impugned order - this cost auditor report has not been placed on record by either side but if the cost auditor report had concluded that the Appellants were not related then definitely Commissioner should have recorded the reasons for rejecting the said report. - AT
Valuation- inter-connected undertaking - related parties or not - applicability of doctrine of mutuality of interest - The fact that Appellant 1 and Appellant 2 were not related person has been brought out in the cost auditor report received by the department on 31.12.2007, as recorded while recording the submissions of the appellant in the impugned order - this cost auditor report has not been placed on record by either side but if the cost auditor report had concluded that the Appellants were not related then definitely Commissioner should have recorded the reasons for rejecting the said report. - AT
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