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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Clandestine production and removal - onus to prove - The submission of the revenue that by the recovery of the notebooks, they have discharged the burden and the onus to prove thereafter shifts on the assessee is erroneous as it has been repeatedly observed that merely on seized records, the charge of clandestine removal is not sustainable unless the same is corroborated by other substantive and independent evidence. The seized record from the residence of Sri S.V.S. Sarma cannot be related to the business accounts of NIPL. - AT
Clandestine production and removal - onus to prove - The submission of the revenue that by the recovery of the notebooks, they have discharged the burden and the onus to prove thereafter shifts on the assessee is erroneous as it has been repeatedly observed that merely on seized records, the charge of clandestine removal is not sustainable unless the same is corroborated by other substantive and independent evidence. The seized record from the residence of Sri S.V.S. Sarma cannot be related to the business accounts of NIPL. - AT
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