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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Classification of services - job work in the factory premises - service provider provided the manufacturing activity in the factory of service recipient with the help of his own workers and it was held that service is of not Manpower Recruitment or Supply Agency Service but it is job work. - AT
Classification of services - job work in the factory premises - service provider provided the manufacturing activity in the factory of service recipient with the help of his own workers and it was held that service is of not Manpower Recruitment or Supply Agency Service but it is job work. - AT
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