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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Disallowance of additional depreciation - the fact remains as per this proviso the assessee is only required to acquire and install the machines, which in this case has been rightly done so by the assessee and is duly supported by the certificate of the Chartered Engineer as well as of Chartered Accountant which proves that the assessee has purchased the machines and installed the same and this resulted in increase in installed capacity of production of the assessee and, therefore, assessee is eligible for claiming the additional depreciation. - AT
Disallowance of additional depreciation - the fact remains as per this proviso the assessee is only required to acquire and install the machines, which in this case has been rightly done so by the assessee and is duly supported by the certificate of the Chartered Engineer as well as of Chartered Accountant which proves that the assessee has purchased the machines and installed the same and this resulted in increase in installed capacity of production of the assessee and, therefore, assessee is eligible for claiming the additional depreciation. - AT
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