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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Depreciation - Determination of cost of acquisition - Reduction of amount of subsidy - Explanation 10 to section 43(1) - the said section is not applicable on the facts of the case in hand in as much as the subsidy has not been granted for meeting cost of any asset but for larger public interest of industrial development of the State of Punjab. - Further, even if the action of the Assessing Officer has to be accepted, then the same should have been taken in A.Y 1999-2000, and not after a gap of 10 years - AT
Depreciation - Determination of cost of acquisition - Reduction of amount of subsidy - Explanation 10 to section 43(1) - the said section is not applicable on the facts of the case in hand in as much as the subsidy has not been granted for meeting cost of any asset but for larger public interest of industrial development of the State of Punjab. - Further, even if the action of the Assessing Officer has to be accepted, then the same should have been taken in A.Y 1999-2000, and not after a gap of 10 years - AT
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