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 expenditure of sales commission - genuineness of expenditure - Nonetheless except for this agreement, the assessee not produced any invoice or voucher of the sales commission neither furnished quantitative details or details of sales of which commission had been computed and paid. - Additions confirmed - AT
Disallowance of expenditure of sales commission - genuineness of expenditure - Nonetheless except for this agreement, the assessee not produced any invoice or voucher of the sales commission neither furnished quantitative details or details of sales of which commission had been computed and paid. - Additions confirmed - AT
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