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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Disallowance of depreciation on vehicle on the ground of personal use - Once the claim of depreciation on passenger vehicle is accepted by the AO then the depreciation on delivery van cannot be disallowed on the ground of personal use. AO has otherwise made this disallowance on presumption and surmises without the actual fact of the use of the vehicle. Even otherwise the delivery van is hardly used for personal purpose and can be used only for the business purpose of the assessee. - AT
Disallowance of depreciation on vehicle on the ground of personal use - Once the claim of depreciation on passenger vehicle is accepted by the AO then the depreciation on delivery van cannot be disallowed on the ground of personal use. AO has otherwise made this disallowance on presumption and surmises without the actual fact of the use of the vehicle. Even otherwise the delivery van is hardly used for personal purpose and can be used only for the business purpose of the assessee. - AT
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