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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Penalty u/s 271 (1)(c) - capital gain assessed as per the provisions of section 50C/2(14) - The direction of CIT(A) is clear that penalty cannot be imposed on the basis of legal fiction of section 50C - He therefore, directed to work out the concealed capital gain in accordance with the sale value of the property - No infirmity into the direction of CIT(A). It would be open before the AO even to decide whether the land in question was a capital asset or not. - AT
Penalty u/s 271 (1)(c) - capital gain assessed as per the provisions of section 50C/2(14) - The direction of CIT(A) is clear that penalty cannot be imposed on the basis of legal fiction of section 50C - He therefore, directed to work out the concealed capital gain in accordance with the sale value of the property - No infirmity into the direction of CIT(A). It would be open before the AO even to decide whether the land in question was a capital asset or not. - AT
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