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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Clubbing of income u/s 64 - Additions of Sale proceeds of the land belonging to the assessee’s wife claimed to be credited to the assessee’s bank account - Wife has no independent source of income, for her to acquire the said land. Even otherwise, it is apparent that the assessee is managing all the funds belonging to him and his wife - As a corollary, all the income arising to the assessee’s wife would stand to be assessed in his hands, statutorily mandated u/s. 64 of the Act. - AT
Clubbing of income u/s 64 - Additions of Sale proceeds of the land belonging to the assessee’s wife claimed to be credited to the assessee’s bank account - Wife has no independent source of income, for her to acquire the said land. Even otherwise, it is apparent that the assessee is managing all the funds belonging to him and his wife - As a corollary, all the income arising to the assessee’s wife would stand to be assessed in his hands, statutorily mandated u/s. 64 of the Act. - AT
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