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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HC held that u/s 40A, cash payments are restricted to prevent false income claims. Exemptions allowed for special circumstances where bank transactions are impossible. Assessee must prove cash payment necessity and no income escape. Cloth business failed to show exigency for cash payments on last day of assessment year. Lack of evidence on payments and income declaration led to dismissal of WP. Onus on assessee to prove compliance with cash payment restrictions.
HC held that u/s 40A, cash payments are restricted to prevent false income claims. Exemptions allowed for special circumstances where bank transactions are impossible. Assessee must prove cash payment necessity and no income escape. Cloth business failed to show exigency for cash payments on last day of assessment year. Lack of evidence on payments and income declaration led to dismissal of WP. Onus on assessee to prove compliance with cash payment restrictions.
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