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 reopening order passed without dealing with assessee's submission - The Income Tax Appellate Tribunal (ITAT) had previously ruled in favor of the petitioner in a similar case for the assessment year 2011-2012. The High Court affirmed the ITAT's decision, stating that since the members had already paid taxes on the compensation received, there should not be double taxation. The court also emphasized that the petitioner had entered into the development agreement on behalf of its members, and the compensations were meant for them. - s the order failed to consider the petitioner's explanations regarding the nature of the income and its taxability, the court concluded that it could not be sustained.
Validity of reopening order passed without dealing with assessee's submission - The Income Tax Appellate Tribunal (ITAT) had previously ruled in favor of the petitioner in a similar case for the assessment year 2011-2012. The High Court affirmed the ITAT's decision, stating that since the members had already paid taxes on the compensation received, there should not be double taxation. The court also emphasized that the petitioner had entered into the development agreement on behalf of its members, and the compensations were meant for them. - s the order failed to consider the petitioner's explanations regarding the nature of the income and its taxability, the court concluded that it could not be sustained.
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