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 short term capital loss aroused on the forfeiture of share warrant money - additions u/s 68 - since all the details of the flow of funds was before the assessing officer he has not been able to point out as to which stage and in what respect ingredients of section 68 are not cogently satisfied. There is no mention as to whether the identity is not available, or that the source of funds is not given, or that Assessing Officer has unearthed some other transactions. Hence the assessing officer's order is only based upon surmises and conjecture and hence it is not sustainable in law. - AT
Disallowance of short term capital loss aroused on the forfeiture of share warrant money - additions u/s 68 - since all the details of the flow of funds was before the assessing officer he has not been able to point out as to which stage and in what respect ingredients of section 68 are not cogently satisfied. There is no mention as to whether the identity is not available, or that the source of funds is not given, or that Assessing Officer has unearthed some other transactions. Hence the assessing officer's order is only based upon surmises and conjecture and hence it is not sustainable in law. - AT
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