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 of payments made through credit card - payment was made by Company and recorded by Company in its books of account - when the assessee was consistently claiming that he is not able to explain the difference in absence of full details of Information Report, either the departmental authorities should have provided full information to assessee to enable him to delve into the difference or else they should have accepted the assessee’s simpliciter explanation that difference could not be reconciled in absence of full information. - AT
Addition of payments made through credit card - payment was made by Company and recorded by Company in its books of account - when the assessee was consistently claiming that he is not able to explain the difference in absence of full details of Information Report, either the departmental authorities should have provided full information to assessee to enable him to delve into the difference or else they should have accepted the assessee’s simpliciter explanation that difference could not be reconciled in absence of full information. - AT
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