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 of expenditure on salary and wages - establishment of nexus between the expenditure and the purpose of business - The assessee’s claim in the instant case is wholly unsubstantiated. No explanation, much less material, stands furnished before the AO. How, pray, could his action be faulted within law? He was accordingly well within his powers to make a reasonable estimate and disallow what he regarded as excessive or as not explained. - Order of CIT(A) deleting the additions set aside - AT
Disallowance of expenditure on salary and wages - establishment of nexus between the expenditure and the purpose of business - The assessee’s claim in the instant case is wholly unsubstantiated. No explanation, much less material, stands furnished before the AO. How, pray, could his action be faulted within law? He was accordingly well within his powers to make a reasonable estimate and disallow what he regarded as excessive or as not explained. - Order of CIT(A) deleting the additions set aside - AT
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