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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The High Court rejected settlement applications by appellants for suppressing income, following the demise of the original assessee. The Settlement Commission found shortcomings in income disclosure, including lack of details on foreign accounts, investments, and business activities. The Commission observed non-cooperation in explaining transactions, leading to rejection of settlements. The Court upheld the Commission's decision, stating that factual findings should not be interfered with unless there is a clear error. Restraint was advised in challenging the Commission's order. The writ petitions filed by the appellants were dismissed by the Court.
The High Court rejected settlement applications by appellants for suppressing income, following the demise of the original assessee. The Settlement Commission found shortcomings in income disclosure, including lack of details on foreign accounts, investments, and business activities. The Commission observed non-cooperation in explaining transactions, leading to rejection of settlements. The Court upheld the Commission's decision, stating that factual findings should not be interfered with unless there is a clear error. Restraint was advised in challenging the Commission's order. The writ petitions filed by the appellants were dismissed by the Court.
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