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 accommodation entry receipts - Bogus penny stock transaction - after again having made the disclosure, the assessee tried to cover the amount by claim of expenditure, which were totally an afterthought and assessee could not support the same despite opportunity. - the new plank raised in set aside proceedings has also been correctly rejected by the ld. CIT(A). Firstly, the assessee could not have made a fresh claim and moreover the same also was only ipse dixit, without proper corroborative material. - AT
Bogus accommodation entry receipts - Bogus penny stock transaction - after again having made the disclosure, the assessee tried to cover the amount by claim of expenditure, which were totally an afterthought and assessee could not support the same despite opportunity. - the new plank raised in set aside proceedings has also been correctly rejected by the ld. CIT(A). Firstly, the assessee could not have made a fresh claim and moreover the same also was only ipse dixit, without proper corroborative material. - AT
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