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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Validity of faceless assessment - allegation of the petitioner that it did not have the opportunity of being heard by the assessing officer - Liberty granted to the petitioner herein to avail the remedy of filing a statutory appellate remedy. In the event, the petitioner avails such a remedy and is under an obligation to make a pre-deposit before the said authority, an application may be made seeking waiver or reduction in the deposit to be made, as the case may be. - SC
Validity of faceless assessment - allegation of the petitioner that it did not have the opportunity of being heard by the assessing officer - Liberty granted to the petitioner herein to avail the remedy of filing a statutory appellate remedy. In the event, the petitioner avails such a remedy and is under an obligation to make a pre-deposit before the said authority, an application may be made seeking waiver or reduction in the deposit to be made, as the case may be. - SC
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