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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Dishonor of Cheque - insufficiency of funds - It cannot be stated that the respondent has failed to prove that the cheque in question was not dishonoured for insufficiency of funds. In any case, if petitioner had sufficient funds in his account at the relevant time, it was always open to him to produce statement of account while leading his evidence in defence. Having failed to do so, it has to be presumed that whatever is stated in the memo of dishonour of cheque in question is correct. - HC
Dishonor of Cheque - insufficiency of funds - It cannot be stated that the respondent has failed to prove that the cheque in question was not dishonoured for insufficiency of funds. In any case, if petitioner had sufficient funds in his account at the relevant time, it was always open to him to produce statement of account while leading his evidence in defence. Having failed to do so, it has to be presumed that whatever is stated in the memo of dishonour of cheque in question is correct. - HC
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