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 reviewed a case involving a rough assessment of tax quantum and the validity of a Best judgment assessment for determining net profit in a civil work contract. The assessing officer acknowledged the receipt of consideration for civil work, which was supported by materials not disputed. The ITAT noted the net profit rates of the past seven years and comparable rates in the trade, settling on a rate of 8% agreed upon by the assessee. The court found no fault in the application of the 8% net profit rate, upholding the ITAT's decision as legally sound. The judgment favored the assessee based on best judgment assessment principles.
The High Court reviewed a case involving a rough assessment of tax quantum and the validity of a Best judgment assessment for determining net profit in a civil work contract. The assessing officer acknowledged the receipt of consideration for civil work, which was supported by materials not disputed. The ITAT noted the net profit rates of the past seven years and comparable rates in the trade, settling on a rate of 8% agreed upon by the assessee. The court found no fault in the application of the 8% net profit rate, upholding the ITAT's decision as legally sound. The judgment favored the assessee based on best judgment assessment principles.
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