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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Assessment u/s 153A - Additions made in original assessment u/s 143(3) of the Act again added back in the assessment completed u/s 153A/143(3) , Disallowance of loss incurred by SEZ added u/s 115JB, Disallowance of deduction claimed u/s 35(2AB) , Expenditure by way of tax paid on ESOP added u/s 115JB - The Tribunal's reinforces the necessity of basing additions and disallowances on incriminating material discovered during search operations, especially in unabated assessment years. Furthermore, it emphasizes the importance of evidentiary value and the principles of natural justice in the assessment process. The decision also delineates the boundaries of allowable deductions and the computation of taxable income in light of dubious transactions and flagged suppliers, adhering to established legal precedents.
Assessment u/s 153A - Additions made in original assessment u/s 143(3) of the Act again added back in the assessment completed u/s 153A/143(3) , Disallowance of loss incurred by SEZ added u/s 115JB, Disallowance of deduction claimed u/s 35(2AB) , Expenditure by way of tax paid on ESOP added u/s 115JB - The Tribunal's reinforces the necessity of basing additions and disallowances on incriminating material discovered during search operations, especially in unabated assessment years. Furthermore, it emphasizes the importance of evidentiary value and the principles of natural justice in the assessment process. The decision also delineates the boundaries of allowable deductions and the computation of taxable income in light of dubious transactions and flagged suppliers, adhering to established legal precedents.
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