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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Capital gain computation - addition u/s 50C - DVO has done the valuation in a very arbitrary manner. He has preferred rates of nearby plots despite noting himself an instance of lower rate in the same building. When this was pointed out to Ld. CIT(A) by the assessee, CIT(A) rejected the same by holding valuation adopted by assessee’s valuer also has no value - The view is also supported by the newspaper articles referred by the valuer that the actual prevailing transaction rate in the area were much lower than the circle rate - AT
Capital gain computation - addition u/s 50C - DVO has done the valuation in a very arbitrary manner. He has preferred rates of nearby plots despite noting himself an instance of lower rate in the same building. When this was pointed out to Ld. CIT(A) by the assessee, CIT(A) rejected the same by holding valuation adopted by assessee’s valuer also has no value - The view is also supported by the newspaper articles referred by the valuer that the actual prevailing transaction rate in the area were much lower than the circle rate - AT
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