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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Disallowing the loss u/s 79 - change in shareholding of the assessee company - any loss that is coming from the assessment year 2013-14 is not allowable against the income of the assessment year 2014-15. This does not mean that the losses incurred during the assessment year 2014-15 (in the financial year 2013-14) are not to be allowed to be carried forward. With this view of the matter, we find that the observations of the authorities below that the current year losses are not to be allowed to be carried forward further are untenable. - AT
Disallowing the loss u/s 79 - change in shareholding of the assessee company - any loss that is coming from the assessment year 2013-14 is not allowable against the income of the assessment year 2014-15. This does not mean that the losses incurred during the assessment year 2014-15 (in the financial year 2013-14) are not to be allowed to be carried forward. With this view of the matter, we find that the observations of the authorities below that the current year losses are not to be allowed to be carried forward further are untenable. - AT
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