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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Disallowance of bonus paid to directors u/s 36(1)(ii) - assessee paid a bonus in addition to the remuneration to two of its directors - The revenue contended that bonus payment was a tax avoidance scheme. The tribunal analyzed the law and precedent, ruling in favor of the appellant, citing legitimate compensation grounds. The conversion of limited scrutiny and penalty initiation were considered premature and thus not upheld.
Disallowance of bonus paid to directors u/s 36(1)(ii) - assessee paid a bonus in addition to the remuneration to two of its directors - The revenue contended that bonus payment was a tax avoidance scheme. The tribunal analyzed the law and precedent, ruling in favor of the appellant, citing legitimate compensation grounds. The conversion of limited scrutiny and penalty initiation were considered premature and thus not upheld.
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