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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Addition u/s. 36(1)(viia) - maintainability of the provision for bad and doubtful debts, as well as for overdue interest, as claimed by the assessee, a cooperative bank - The assessee having credited the interest income in its’ accounts for the relevant year/s, the same, even though not received, is to be, in terms of s. 43D itself, regarded as the income for the relevant year/s, i.e., the year/s in which it stands recognized as income by crediting the same to its’ P&L A/c. - AT
Addition u/s. 36(1)(viia) - maintainability of the provision for bad and doubtful debts, as well as for overdue interest, as claimed by the assessee, a cooperative bank - The assessee having credited the interest income in its’ accounts for the relevant year/s, the same, even though not received, is to be, in terms of s. 43D itself, regarded as the income for the relevant year/s, i.e., the year/s in which it stands recognized as income by crediting the same to its’ P&L A/c. - AT
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