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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Addition u/s 41 - sick company - cessation of liability towards unsecured loans availed from financial institutions in terms of order of the BIFR - Apex Court has held that, waiver of loan for acquiring capital assets cannot be treated as remission of trading liability and brought to tax u/s. 41(1) or u/s.28(iv) - AO has erred in assessing cessation of liability towards unsecured loans availed from financial institutions in terms of order of the BIFR u/s.41(1) of the Income Tax Act, 1961. - AT
Addition u/s 41 - sick company - cessation of liability towards unsecured loans availed from financial institutions in terms of order of the BIFR - Apex Court has held that, waiver of loan for acquiring capital assets cannot be treated as remission of trading liability and brought to tax u/s. 41(1) or u/s.28(iv) - AO has erred in assessing cessation of liability towards unsecured loans availed from financial institutions in terms of order of the BIFR u/s.41(1) of the Income Tax Act, 1961. - AT
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