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 271AAB - assessee has disclosed the income after the search - in the assessment order penalty was initiated for the marriage expenses of the son for which no addition is made and the AO failed to record the satisfaction so as to whether the income disclosed were undisclosed income of the assessee or not the levy of the penalty is unsustainable in law. - AT
Addition u/s 271AAB - assessee has disclosed the income after the search - in the assessment order penalty was initiated for the marriage expenses of the son for which no addition is made and the AO failed to record the satisfaction so as to whether the income disclosed were undisclosed income of the assessee or not the levy of the penalty is unsustainable in law. - AT
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