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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Disallowance of Provision for Warranty - Absence of scientific method adopted by the assessee - The assessee has submitted that the period of warranty is maximum for one to three years, if the provision for warranty is unutilized for more than three years from the date of commencement of warranty of the products, it should be reversed and offered for taxation in the year of expiry of warranty. - AO directed to verify the claim - AT
Disallowance of Provision for Warranty - Absence of scientific method adopted by the assessee - The assessee has submitted that the period of warranty is maximum for one to three years, if the provision for warranty is unutilized for more than three years from the date of commencement of warranty of the products, it should be reversed and offered for taxation in the year of expiry of warranty. - AO directed to verify the claim - AT
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