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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Gross profit on deficit of stock - Disclosure made by the assessee during the survey operation - survey operation under section 133A on the premises of the assessee - Assessee has not discharged its onus by producing the primary documents in support of its contention. The primary onus lies on the person who asserts the preposition and not on the person who denies. - AT
Gross profit on deficit of stock - Disclosure made by the assessee during the survey operation - survey operation under section 133A on the premises of the assessee - Assessee has not discharged its onus by producing the primary documents in support of its contention. The primary onus lies on the person who asserts the preposition and not on the person who denies. - AT
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