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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Penalty u/s 271-D and 271-E - accepting loan in cash from the director of the company - The tribunal held that, the assessee`s case under consideration the transactions between Directors and assessee-company are on account of business exigency. Besides, assessee-company and the director both have disclosed transactions in their respective books of accounts for the relevant previous year. In the assessee`s case, it was not a case of loan taken/given from/to public, but amount received/paid to director to meet the business exigencies.
Penalty u/s 271-D and 271-E - accepting loan in cash from the director of the company - The tribunal held that, the assessee`s case under consideration the transactions between Directors and assessee-company are on account of business exigency. Besides, assessee-company and the director both have disclosed transactions in their respective books of accounts for the relevant previous year. In the assessee`s case, it was not a case of loan taken/given from/to public, but amount received/paid to director to meet the business exigencies.
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