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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Deduction u/s 80IC - manufacturing of plastic packaging products such as PET and HDPE bottles, jars, caps and closures - products manufactured by the assessee come within Schedule 13 or not - There is no other specific reason or observation by the departmental authorities for denial of assessee’s claim of deduction under section 80IC - Commissioner (Appeals) has made a general observation that the assessee failed to furnish required details without specifying, what are the details required to be furnished by the assessee. - Thus disallowance of deduction claimed by the assessee under section 80IC of the Act is unsustainable - AT
Deduction u/s 80IC - manufacturing of plastic packaging products such as PET and HDPE bottles, jars, caps and closures - products manufactured by the assessee come within Schedule 13 or not - There is no other specific reason or observation by the departmental authorities for denial of assessee’s claim of deduction under section 80IC - Commissioner (Appeals) has made a general observation that the assessee failed to furnish required details without specifying, what are the details required to be furnished by the assessee. - Thus disallowance of deduction claimed by the assessee under section 80IC of the Act is unsustainable - AT
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