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 challan paid in the name of one employee & disallowing the subvend fee paid - CIT-A deleted the addition - as submitted assessee has obtained liquor vend under reserve quota through his employee who was used as dummy bidder and the entire purchases and sale and expenditure was incurred by the assessee - Since the said model of business itself is in violation of licenses issued by the Excise Department, the license fee paid by the assessee who is not the license holder cannot be treated as eligible expenses - Revenue appeal allowed - AT
Disallowing the challan paid in the name of one employee & disallowing the subvend fee paid - CIT-A deleted the addition - as submitted assessee has obtained liquor vend under reserve quota through his employee who was used as dummy bidder and the entire purchases and sale and expenditure was incurred by the assessee - Since the said model of business itself is in violation of licenses issued by the Excise Department, the license fee paid by the assessee who is not the license holder cannot be treated as eligible expenses - Revenue appeal allowed - AT
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