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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Addition u/s 68 - genuineness and credit worthiness of the transaction in question - As per HC assessee though has disclosed the source of the deposit but could not establish the nature thereof and conditions which are required to be proved by the Assessee as per Section 68 could not be proved by him - Apex Court dismissed the SLP of the assessee (Additions confirmed) - SC
Addition u/s 68 - genuineness and credit worthiness of the transaction in question - As per HC assessee though has disclosed the source of the deposit but could not establish the nature thereof and conditions which are required to be proved by the Assessee as per Section 68 could not be proved by him - Apex Court dismissed the SLP of the assessee (Additions confirmed) - SC
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