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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Nature of expenditure - Personal or business expenses - As rightly pointed out by the AO, the immediate beneficiary of the sponsorship was the hospital and not the assessee. Similarly musical program organized for fellow colleagues is nothing but a social event which though helps in promoting the assessee but not only on his professional front but also personal front. This fact cannot be denied. So also the gifts given on marriages and diwali which have been rightly pointed out by the Revenue authorities as being incurred out of social obligations and conventions.- AT
Nature of expenditure - Personal or business expenses - As rightly pointed out by the AO, the immediate beneficiary of the sponsorship was the hospital and not the assessee. Similarly musical program organized for fellow colleagues is nothing but a social event which though helps in promoting the assessee but not only on his professional front but also personal front. This fact cannot be denied. So also the gifts given on marriages and diwali which have been rightly pointed out by the Revenue authorities as being incurred out of social obligations and conventions.- AT
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