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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Computation of capital gain - sale of land in two parts [different AYs] - We agree with the contention of assessee that when a part of the land i.e. 5.74 acres out of the total area of 8.66 acres was sold in A.Y 2013-14 and the remaining part of 2.92 acres of land was sold in A.Y 2014-15, the AO instead of taking the value of the land in acres could not have taken the value per sft which is for developed land with internal roads etc. - AT
Computation of capital gain - sale of land in two parts [different AYs] - We agree with the contention of assessee that when a part of the land i.e. 5.74 acres out of the total area of 8.66 acres was sold in A.Y 2013-14 and the remaining part of 2.92 acres of land was sold in A.Y 2014-15, the AO instead of taking the value of the land in acres could not have taken the value per sft which is for developed land with internal roads etc. - AT
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