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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Maintainability of application - in any case the definition of advance ruling does not permit making of an application in relation to the supply of services already undertaken for a long period of two years in pursuance of an agreement which had expired long before the making of the application seeking advance ruling - the questions involving claim of extension of the two years contract agreement for supply of service for further period of one and a half years, creation of such an extension document at a stage far later than the date of filing application seeking advance ruling and non-existence of evidence showing submission of such an extension letter to the AAR lose their relevance - AAAR
Maintainability of application - in any case the definition of advance ruling does not permit making of an application in relation to the supply of services already undertaken for a long period of two years in pursuance of an agreement which had expired long before the making of the application seeking advance ruling - the questions involving claim of extension of the two years contract agreement for supply of service for further period of one and a half years, creation of such an extension document at a stage far later than the date of filing application seeking advance ruling and non-existence of evidence showing submission of such an extension letter to the AAR lose their relevance - AAAR
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