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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Rectification u/s 154 - The Assessee filed a rectification application, which was dismissed by the CIT(A) based on the assumption of Tribunal's adjudication on the issue. - The Appellate Tribunal concluded that the CIT(A) had erroneously assumed that the issue of unexplained cash was adjudicated upon by the Tribunal. The Tribunal emphasized that the Tribunal's decision focused solely on the jewellery aspect, without any discussion on the unexplained cash addition. - CIT(A) directed for fresh consideration.
Rectification u/s 154 - The Assessee filed a rectification application, which was dismissed by the CIT(A) based on the assumption of Tribunal's adjudication on the issue. - The Appellate Tribunal concluded that the CIT(A) had erroneously assumed that the issue of unexplained cash was adjudicated upon by the Tribunal. The Tribunal emphasized that the Tribunal's decision focused solely on the jewellery aspect, without any discussion on the unexplained cash addition. - CIT(A) directed for fresh consideration.
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