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 in view of the Provisions of section 50C on the Gift of Plots - Transfer of property by a Company as a gift - AO concluded how the gift by one company to other company can be genuine, considering the fact that the company is an Artificial Judicial Person and the element of “natural love and affection” cannot be exist - The department made an addition under Section 50C regarding the gift of plots. The appellant argued that the transfer of property act allows for such gifts, and cited relevant legal provisions and case law. The appellate tribunal upheld the appellant's contention, deleting the addition made by the Assessing Officer.
Addition in view of the Provisions of section 50C on the Gift of Plots - Transfer of property by a Company as a gift - AO concluded how the gift by one company to other company can be genuine, considering the fact that the company is an Artificial Judicial Person and the element of “natural love and affection” cannot be exist - The department made an addition under Section 50C regarding the gift of plots. The appellant argued that the transfer of property act allows for such gifts, and cited relevant legal provisions and case law. The appellate tribunal upheld the appellant's contention, deleting the addition made by the Assessing Officer.
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