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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Rectification u/s 154 - addition u/s 69 r.w.s. 115BBE - disallowing 30% of the expenditure pertaining to salary, rent, contract and professional fee as per Section 40 (a) (ia) - The power of rectification of an order of assessment u/s 154 lies within a very narrow compass. The order to be rectified must be an order which reflects an error apparent on the face of the record. The error or mistake which would require determination after long drawn hearing would not come within the ambit of Section 154. - HC
Rectification u/s 154 - addition u/s 69 r.w.s. 115BBE - disallowing 30% of the expenditure pertaining to salary, rent, contract and professional fee as per Section 40 (a) (ia) - The power of rectification of an order of assessment u/s 154 lies within a very narrow compass. The order to be rectified must be an order which reflects an error apparent on the face of the record. The error or mistake which would require determination after long drawn hearing would not come within the ambit of Section 154. - HC
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