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 Appellate Tribunal considered an issue related to the disallowance of expenditure in cash exceeding the permissible limit u/s 40A. The assessee, a milk distributor, received milk products from a main supplier and conducted sales through sub-distributors, with payments made in cash through banking channels. Despite high turnover and low margins, the Tribunal referred to relevant case precedents to establish that payments made to others could be verified, thus exempting them from section 40A(3). It was found that the payee had also acted as the assessee's agent and was required to make cash payments to the company, leading to the deletion of the disallowance. The decision favored the assessee based on the provided evidence and legal interpretations.
The Appellate Tribunal considered an issue related to the disallowance of expenditure in cash exceeding the permissible limit u/s 40A. The assessee, a milk distributor, received milk products from a main supplier and conducted sales through sub-distributors, with payments made in cash through banking channels. Despite high turnover and low margins, the Tribunal referred to relevant case precedents to establish that payments made to others could be verified, thus exempting them from section 40A(3). It was found that the payee had also acted as the assessee's agent and was required to make cash payments to the company, leading to the deletion of the disallowance. The decision favored the assessee based on the provided evidence and legal interpretations.
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