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...
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Revision u/s 263 by CIT - AO has noted that details of expenses relating to business promotion, lease rent, commission, petrol, travelling etc. were filed by the assessee and which were checked. Therefore, in view of these facts and circumstances, we find that the Assessing Officer had carried out sufficient examination of the expenses relating to site & wages and therefore, passing of order u/s 263 on this account is also not justified. - AT
Revision u/s 263 by CIT - AO has noted that details of expenses relating to business promotion, lease rent, commission, petrol, travelling etc. were filed by the assessee and which were checked. Therefore, in view of these facts and circumstances, we find that the Assessing Officer had carried out sufficient examination of the expenses relating to site & wages and therefore, passing of order u/s 263 on this account is also not justified. - AT
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