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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Penalty proceedings u/s. 271E - conversion of loan into redeemable convertible bonds and therefore, it was observed that the repayment of loan is other than the modes prescribed u/s. 269T - the assessment which already stand completed and loans wherein it has been accepted in their hands prior to the amalgamation, then we do not find any reason or occasion as to why such loans are to be doubted in the hands of the amalgamated company and specifically in the proceedings u/s. 271E. - No penalty - AT
Penalty proceedings u/s. 271E - conversion of loan into redeemable convertible bonds and therefore, it was observed that the repayment of loan is other than the modes prescribed u/s. 269T - the assessment which already stand completed and loans wherein it has been accepted in their hands prior to the amalgamation, then we do not find any reason or occasion as to why such loans are to be doubted in the hands of the amalgamated company and specifically in the proceedings u/s. 271E. - No penalty - AT
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