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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Validity of TPO order u/s 92CA - Period of limitation u/s 153(3) - The High court found the final order of assessment dated 13 February 2023 was indeed passed beyond the statutory time limit and was thus liable to be set aside. It also noted that the adjustments made against refunds for earlier assessment years were improper, as there was no valid demand for A.Y. 2011-12 at the time of those adjustments.
Validity of TPO order u/s 92CA - Period of limitation u/s 153(3) - The High court found the final order of assessment dated 13 February 2023 was indeed passed beyond the statutory time limit and was thus liable to be set aside. It also noted that the adjustments made against refunds for earlier assessment years were improper, as there was no valid demand for A.Y. 2011-12 at the time of those adjustments.
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