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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Interest on delayed refund - relevant date for calculation of refund - No justification for the bifurcation have been given while sanctioning the interest only on the amount of pre deposit has been given in the order. It is also observed that the findings of the claim to be barred by time are also not correct as the relevant date for recovery period is considered as date of filing the appeal (i.e. 01.09.2014). Inspite of date of communication of the final order entitling the appellant from the impugned relief, 30.6.2017. - Claim of interest allowed - AT
Interest on delayed refund - relevant date for calculation of refund - No justification for the bifurcation have been given while sanctioning the interest only on the amount of pre deposit has been given in the order. It is also observed that the findings of the claim to be barred by time are also not correct as the relevant date for recovery period is considered as date of filing the appeal (i.e. 01.09.2014). Inspite of date of communication of the final order entitling the appellant from the impugned relief, 30.6.2017. - Claim of interest allowed - AT
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