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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Bogus purchases - addition made towards entire bogus purchase - Assessee has literally wasted precious time of the AO by once again issuing notices and summons to the third parties and at the end of the proceedings, the assessee expressed inability to prove before the AO the genuineness of the transactions. Thus, both the AO and the CIT(A) have given clear cut finding that the assessee could not able to prove the purchases as genuine - AT
Bogus purchases - addition made towards entire bogus purchase - Assessee has literally wasted precious time of the AO by once again issuing notices and summons to the third parties and at the end of the proceedings, the assessee expressed inability to prove before the AO the genuineness of the transactions. Thus, both the AO and the CIT(A) have given clear cut finding that the assessee could not able to prove the purchases as genuine - AT
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