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 of assessment u/s 147 - Reason to believe - Addition u/s 69C on account of the capital introduced by the partner and unsecured loans - The Tribunal upheld the validity of the reassessment proceedings, citing the absence of a request for reasons during the assessment or appellate proceedings. However, it ruled in favor of the Assessee regarding the additions under section 69C. The Tribunal emphasized the Assessee's compliance with providing evidence and shifted the onus to the AO to justify rejecting the explanations provided.
Validity of reopening of assessment u/s 147 - Reason to believe - Addition u/s 69C on account of the capital introduced by the partner and unsecured loans - The Tribunal upheld the validity of the reassessment proceedings, citing the absence of a request for reasons during the assessment or appellate proceedings. However, it ruled in favor of the Assessee regarding the additions under section 69C. The Tribunal emphasized the Assessee's compliance with providing evidence and shifted the onus to the AO to justify rejecting the explanations provided.
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