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 u/s 68 - buyback was not genuine and added back the buyback amount as unexplained income - Section 68 of the Income Tax Act, 1961, which deals with unexplained credits, was found inapplicable as the transaction was genuine, and the identity and creditworthiness of the company were established. - The tribunal upheld the findings of the Commissioner of Income Tax (Appeals) that the income arising from the buyback of shares was exempt under Section 10(34A) of the Act.
Addition u/s 68 - buyback was not genuine and added back the buyback amount as unexplained income - Section 68 of the Income Tax Act, 1961, which deals with unexplained credits, was found inapplicable as the transaction was genuine, and the identity and creditworthiness of the company were established. - The tribunal upheld the findings of the Commissioner of Income Tax (Appeals) that the income arising from the buyback of shares was exempt under Section 10(34A) of the Act.
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