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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Penalty u/s 271(1)(c) - disallowance of excessive depreciation - cost of acquisition of wind mill - whether or not assessee is entitled to the benefit under proviso to Explanation 10 of Section 43(1)? - in order to entail liability for penalty, there has to be satisfaction based on material as required under Section 271(1)(c) of the Act, that the assessee has concealed the particulars of his income or furnished inaccurate particulars of such income. - Department failed to prove that the assessee had submitted inaccurate particulars - No penalty - HC
Penalty u/s 271(1)(c) - disallowance of excessive depreciation - cost of acquisition of wind mill - whether or not assessee is entitled to the benefit under proviso to Explanation 10 of Section 43(1)? - in order to entail liability for penalty, there has to be satisfaction based on material as required under Section 271(1)(c) of the Act, that the assessee has concealed the particulars of his income or furnished inaccurate particulars of such income. - Department failed to prove that the assessee had submitted inaccurate particulars - No penalty - HC
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