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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Allowable business expenditure u/s 37 - Offence for non-compliance of fire safety provisions is heinous which may result into breakage of fire putting risk to life and limb of residents as well as other public at large. Any payment made by the assessee as compounding fees for such an offence has rightly been disallowed by the lower authorities. The assessee in this case right from the Assessing Officer to the level of the Tribunal has tried to misguide authorities about the nature of payment which act of the assessee is highly deprecable. - AT
Allowable business expenditure u/s 37 - Offence for non-compliance of fire safety provisions is heinous which may result into breakage of fire putting risk to life and limb of residents as well as other public at large. Any payment made by the assessee as compounding fees for such an offence has rightly been disallowed by the lower authorities. The assessee in this case right from the Assessing Officer to the level of the Tribunal has tried to misguide authorities about the nature of payment which act of the assessee is highly deprecable. - AT
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