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 on failure to show the “gitty’ expenses in Closing Stock or WIP - addition based on audit objection - goods in transit - the AO passed the order in haste and it seems that the addition is made only for the reasons that some audit objection was raised. We also perused the alleged audit objection and find that such objection is raised without application of mind. The assumption of audit objection might be based on the idea that the office of the assessee is situated in Surat, so the material could be in transit to Surat. Though, the facts on the records were otherwise - CIT(A) rightly deleted the additions - AT
Addition on failure to show the “gitty’ expenses in Closing Stock or WIP - addition based on audit objection - goods in transit - the AO passed the order in haste and it seems that the addition is made only for the reasons that some audit objection was raised. We also perused the alleged audit objection and find that such objection is raised without application of mind. The assumption of audit objection might be based on the idea that the office of the assessee is situated in Surat, so the material could be in transit to Surat. Though, the facts on the records were otherwise - CIT(A) rightly deleted the additions - AT
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