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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Disallowance claimed as bad debt/business loss - rejection of goods in inferior quality by the customers - simply because the customer of the assessee did not respond to notice u/s 133(6) of the Act the mail sent by the customer to the assessee rejecting the goods worth supplied for poor quality cannot be ignored and disbelieved only for the reason that the party did not respond to the notice issued by the AO. - AT
Disallowance claimed as bad debt/business loss - rejection of goods in inferior quality by the customers - simply because the customer of the assessee did not respond to notice u/s 133(6) of the Act the mail sent by the customer to the assessee rejecting the goods worth supplied for poor quality cannot be ignored and disbelieved only for the reason that the party did not respond to the notice issued by the AO. - AT
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