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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Claim of Expenditure on hawala business - Assessee also did not submit any proof of incurring any expenditure. Income was also not assessed on net basis @ 0.30 %. No proof of incurring any expenditure is available on record. Therefore, naturally no expenditure is incurred by assessee. Therefore, the action of the learned CIT – A in granting deduction of 10% of the gross income earned by the assessee is not in conformity with the provisions of Section 37 (1) of the act. - AT
Claim of Expenditure on hawala business - Assessee also did not submit any proof of incurring any expenditure. Income was also not assessed on net basis @ 0.30 %. No proof of incurring any expenditure is available on record. Therefore, naturally no expenditure is incurred by assessee. Therefore, the action of the learned CIT – A in granting deduction of 10% of the gross income earned by the assessee is not in conformity with the provisions of Section 37 (1) of the act. - AT
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