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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Necessity of establishing nexus between expenditure incurred and earning of exempt income u/s 14A read with Rule 8D. Mechanical application of Rule 8D without recording requisite satisfaction violates procedural requirement u/s 14A(2). Disallowance restricted to exempt income earned. Deletion of addition for bogus long-term capital loss upheld due to lack of substantial evidence and failure to provide opportunity for cross-verification. Addition of speculation loss claimed under "income from other sources" dismissed as it represented depreciation related to speculation business, properly accounted for with nullifying effect on returned income. Procedural lapses by Assessing Officer noted.
Necessity of establishing nexus between expenditure incurred and earning of exempt income u/s 14A read with Rule 8D. Mechanical application of Rule 8D without recording requisite satisfaction violates procedural requirement u/s 14A(2). Disallowance restricted to exempt income earned. Deletion of addition for bogus long-term capital loss upheld due to lack of substantial evidence and failure to provide opportunity for cross-verification. Addition of speculation loss claimed under "income from other sources" dismissed as it represented depreciation related to speculation business, properly accounted for with nullifying effect on returned income. Procedural lapses by Assessing Officer noted.
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