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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Additions of surrendered amount as excess stock during the survey proceedings - During assessment proceedings production of stock register was insisted upon, though the assessee in reply to question No. 34 has stated that he is not maintaining any stock register because it involves various sizes, weight and quality of the paper. This statement of the assessee has completely been ignored by the Revenue Authorities. We, therefore, hold that the excess stock as worked out by the survey team does not rest on solid foundation as it has been arrived at by incorrect assumptions. - AT
Additions of surrendered amount as excess stock during the survey proceedings - During assessment proceedings production of stock register was insisted upon, though the assessee in reply to question No. 34 has stated that he is not maintaining any stock register because it involves various sizes, weight and quality of the paper. This statement of the assessee has completely been ignored by the Revenue Authorities. We, therefore, hold that the excess stock as worked out by the survey team does not rest on solid foundation as it has been arrived at by incorrect assumptions. - AT
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