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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Set-off of losses against income from other sources u/s 70 - Applicability of provision of section 10B - petitioner had the status of EOU for a period of 5 years - The High Court upheld the petitioner's contention that Section 10B was not applicable to them as they were a 100% EOU. - The Court, after considering submissions and legal precedents, ruled in favor of the petitioner, declaring the notices and orders as invalid. The Court affirmed the petitioner's right to set off losses under Section 70 and upheld their interpretation of the law.
Set-off of losses against income from other sources u/s 70 - Applicability of provision of section 10B - petitioner had the status of EOU for a period of 5 years - The High Court upheld the petitioner's contention that Section 10B was not applicable to them as they were a 100% EOU. - The Court, after considering submissions and legal precedents, ruled in favor of the petitioner, declaring the notices and orders as invalid. The Court affirmed the petitioner's right to set off losses under Section 70 and upheld their interpretation of the law.
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