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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Valuation - inclusion of value of bought out items - it is found that the bought out items have not been attached with the weigh bridge. Even after installation of the weighbridge, they perform their functions independently. Thus these items are not essential part of the weigh bridge and the value of these bought out items are not includable in the assessable value. - AT
Valuation - inclusion of value of bought out items - it is found that the bought out items have not been attached with the weigh bridge. Even after installation of the weighbridge, they perform their functions independently. Thus these items are not essential part of the weigh bridge and the value of these bought out items are not includable in the assessable value. - AT
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