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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Capital gain - unregistered agreement - transfer of capital asset u/s 2(47) - real owner - deemed owner - CIT(A) has diverted his mind to a wrong provision of law and diverted himself from the ratio decided in Balbir Singh Maini. In the present case, the controversy between parties is precisely for “Income from Business” head and that too whether or not M/s Govind can be said to be owner of land on the basis of unregistered agreement. - The answer is NO - AT
Capital gain - unregistered agreement - transfer of capital asset u/s 2(47) - real owner - deemed owner - CIT(A) has diverted his mind to a wrong provision of law and diverted himself from the ratio decided in Balbir Singh Maini. In the present case, the controversy between parties is precisely for “Income from Business” head and that too whether or not M/s Govind can be said to be owner of land on the basis of unregistered agreement. - The answer is NO - AT
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