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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Addition proposed in the draft assessment order as TP adjustment - Non following mandatory provisions of Sec. 144C while issuing draft assessment order - The ITAT found merit in the assessee's argument, holding that the assessment order was void as the AO failed to follow the mandatory procedure laid down under Section 144C of the Act. The ITAT referred to various judicial precedents, including decisions of the Hon’ble Karnataka High Court and other ITAT decisions, supporting this view.
Addition proposed in the draft assessment order as TP adjustment - Non following mandatory provisions of Sec. 144C while issuing draft assessment order - The ITAT found merit in the assessee's argument, holding that the assessment order was void as the AO failed to follow the mandatory procedure laid down under Section 144C of the Act. The ITAT referred to various judicial precedents, including decisions of the Hon’ble Karnataka High Court and other ITAT decisions, supporting this view.
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