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 68 - bogus liability allegedly shown by the assessee - receipt of the shares on loan - It appears to us that the nature of transactions as well as the modus operandi involved in the same was not properly understood by the AO while doubting the genuineness of the same while CIT(A) not only understood the same properly but also appreciated the exact nature of transactions to hold that the said transactions were genuine which were entered into by the assessee in the normal course of its business as a dealer in shares. - AT
Addition u/s 68 - bogus liability allegedly shown by the assessee - receipt of the shares on loan - It appears to us that the nature of transactions as well as the modus operandi involved in the same was not properly understood by the AO while doubting the genuineness of the same while CIT(A) not only understood the same properly but also appreciated the exact nature of transactions to hold that the said transactions were genuine which were entered into by the assessee in the normal course of its business as a dealer in shares. - AT
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