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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Additions on the basis of material seized during the search in case of third party without adhering to the provisions of section 153C - The tribunal found that the AO had improperly used documents seized from third parties to make additions to the assessee's income. This was ruled inappropriate and beyond the scope of the authority provided under the Income Tax Act, as the procedures laid out under Section 153C (dealing with income or assets discovered in the course of search operations that belong to persons other than the searched party) were not followed.
Additions on the basis of material seized during the search in case of third party without adhering to the provisions of section 153C - The tribunal found that the AO had improperly used documents seized from third parties to make additions to the assessee's income. This was ruled inappropriate and beyond the scope of the authority provided under the Income Tax Act, as the procedures laid out under Section 153C (dealing with income or assets discovered in the course of search operations that belong to persons other than the searched party) were not followed.
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