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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Denial of credit of advance tax paid by assessee - filing of application before CBDT u/s 119(2)(b) for condonation of delay in claiming the advance tax credit - AO erred in not rectifiying this apparent mistake when the same was pointed out by the assessee vide its application under section 154 of the Act. Accordingly, we direct the jurisdictional AO to grant the credit of advance tax paid by the assessee- AT
Denial of credit of advance tax paid by assessee - filing of application before CBDT u/s 119(2)(b) for condonation of delay in claiming the advance tax credit - AO erred in not rectifiying this apparent mistake when the same was pointed out by the assessee vide its application under section 154 of the Act. Accordingly, we direct the jurisdictional AO to grant the credit of advance tax paid by the assessee- AT
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