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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Revision u/s 263 - taxability of income surrendered in the course of survey prescribed u/s 115BBE - The press release does not in any manner reads down the substituted provisions of S. 115BBE which are far wider in its scope and ambit. The salutary principles of charging Section 4 discussed in para 13 above would apply mutatis mutandis. - Twin conditions of Section 263 are not simultaneously satisfied - Revision order set aside - AT
Revision u/s 263 - taxability of income surrendered in the course of survey prescribed u/s 115BBE - The press release does not in any manner reads down the substituted provisions of S. 115BBE which are far wider in its scope and ambit. The salutary principles of charging Section 4 discussed in para 13 above would apply mutatis mutandis. - Twin conditions of Section 263 are not simultaneously satisfied - Revision order set aside - AT
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