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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Estimation of income on Cash Deposited in Bank Account - Kachha Arahtiya - Estimation of Net Profit (NP) @ 5% instead of 1% as claimed by the assessee - so far as kachha arahtias are concerned, the turnover does not include the sales affected on behalf of the principals and only the gross commission has to be considered for the purpose of section 44AB - it would be justified to apply a net profit rate of 1.5% as against 5% applied by the AO, on the Total Turn Over estimated - AT
Estimation of income on Cash Deposited in Bank Account - Kachha Arahtiya - Estimation of Net Profit (NP) @ 5% instead of 1% as claimed by the assessee - so far as kachha arahtias are concerned, the turnover does not include the sales affected on behalf of the principals and only the gross commission has to be considered for the purpose of section 44AB - it would be justified to apply a net profit rate of 1.5% as against 5% applied by the AO, on the Total Turn Over estimated - AT
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