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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Addition u/s 68 - Additions based on the information received from ITO having different Jurisdiction - The Information is just an information for setting the machinery into motion, it cannot be treated as a gospel truth. The issue has to be examined, therefore, AO is directed to look into all these aspects afresh and read judicate the issue after providing due opportunity of hearing to the assessee - AT
Addition u/s 68 - Additions based on the information received from ITO having different Jurisdiction - The Information is just an information for setting the machinery into motion, it cannot be treated as a gospel truth. The issue has to be examined, therefore, AO is directed to look into all these aspects afresh and read judicate the issue after providing due opportunity of hearing to the assessee - AT
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