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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Commission paid to director is allowable business expenditure u/s 36(1)(ii) as assessee provided substantial evidence demonstrating services rendered and resultant benefits; AO failed to prove payment was made to avoid DDT. Weighted deduction claim u/s 35(2AB) allowed in full; AO cannot solely rely on DSIR report without considering assessee's books of accounts and chartered accountant's certification. Principles of natural justice require providing reasons for reducing claim and opportunity to respond.
Commission paid to director is allowable business expenditure u/s 36(1)(ii) as assessee provided substantial evidence demonstrating services rendered and resultant benefits; AO failed to prove payment was made to avoid DDT. Weighted deduction claim u/s 35(2AB) allowed in full; AO cannot solely rely on DSIR report without considering assessee's books of accounts and chartered accountant's certification. Principles of natural justice require providing reasons for reducing claim and opportunity to respond.
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