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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Addition u/s. 56(2)(viib) - premium on issue of equity share - CIT(A), while allowing the appeal of the assessee, is not expected to come to a conclusion based on abstract position of law. No inquiry has been shown to be made towards the basis for determination of projected figures assumed while applying DCF Method. The report of the valuer is also based on disclaimer. - CIT(A) has not acted in the manner ordained in law - Matter restored back - AT
Addition u/s. 56(2)(viib) - premium on issue of equity share - CIT(A), while allowing the appeal of the assessee, is not expected to come to a conclusion based on abstract position of law. No inquiry has been shown to be made towards the basis for determination of projected figures assumed while applying DCF Method. The report of the valuer is also based on disclaimer. - CIT(A) has not acted in the manner ordained in law - Matter restored back - AT
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