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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Deduction of research and development expenses claimed u/s 35(2AB) - weighted deduction - whether the expenditure claimed by the assessee is required to be approved by the DSIR? - The Tribunal held that in view of decision of High Court, AO directed to verify the correctness of the claim of the actual expenses incurred by the assessee in respect of scientific research in-house research and development facility. If the claim of assessee is found to be correct he would delete the impugned disallowance of expenditure.
Deduction of research and development expenses claimed u/s 35(2AB) - weighted deduction - whether the expenditure claimed by the assessee is required to be approved by the DSIR? - The Tribunal held that in view of decision of High Court, AO directed to verify the correctness of the claim of the actual expenses incurred by the assessee in respect of scientific research in-house research and development facility. If the claim of assessee is found to be correct he would delete the impugned disallowance of expenditure.
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