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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Disallowance of depreciation of plant and machinery claimed - As per AO stainless pipes / tubes were never purchased by the assessee and the assessee took accommodation entry to siphon of black money - The appellant could not explain how much other materials such as nuts, bolts, brackets, sockets consumed for fitting/installing the pipes/tubes were accounted for in its books though the AO had called for those details in the course of the assessment proceedings.Taking all these facts into consideration, hold that the appellant's claim regarding purchase of pipes/tubes is not correct. - AT
Disallowance of depreciation of plant and machinery claimed - As per AO stainless pipes / tubes were never purchased by the assessee and the assessee took accommodation entry to siphon of black money - The appellant could not explain how much other materials such as nuts, bolts, brackets, sockets consumed for fitting/installing the pipes/tubes were accounted for in its books though the AO had called for those details in the course of the assessment proceedings.Taking all these facts into consideration, hold that the appellant's claim regarding purchase of pipes/tubes is not correct. - AT
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