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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Correct head of income - letting out of Hotel/Resort as running business - treatment of revenue receipts from operation of Hotel/Resort - Contract for managing the business from the said premises on a consideration of management license basis - No fixed consideration - the revenue receipts are undoubtedly income from the Business and therefore, should be treated under the head “Business Income” but not as rental income from “House Property” - AT
Correct head of income - letting out of Hotel/Resort as running business - treatment of revenue receipts from operation of Hotel/Resort - Contract for managing the business from the said premises on a consideration of management license basis - No fixed consideration - the revenue receipts are undoubtedly income from the Business and therefore, should be treated under the head “Business Income” but not as rental income from “House Property” - AT
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