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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Valuation - inclusion of freight charges - though the authorities below have given the finding that sales were on FOR destination basis but no evidence in this regard has been discussed - the cost of transportation in the given circumstances is the one which has expressly been excluded in terms of Rule 5 of Valuation Rules. - The freight charges are not includible in the assessable value of liquid CO2 those being separately charged in the invoices and the gas was sold at the time of clearance from the factory of the appellant - AT
Valuation - inclusion of freight charges - though the authorities below have given the finding that sales were on FOR destination basis but no evidence in this regard has been discussed - the cost of transportation in the given circumstances is the one which has expressly been excluded in terms of Rule 5 of Valuation Rules. - The freight charges are not includible in the assessable value of liquid CO2 those being separately charged in the invoices and the gas was sold at the time of clearance from the factory of the appellant - AT
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