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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No time limit prescribed u/s 279(2) of Income Tax Act for filing compounding application. CBDT circular fixing 36-month limitation period held contrary to the Act and impermissible. Judgment in Jayshree's case applied, holding CBDT cannot issue circular contrary to the object of statutory provisions. Once an offence is compoundable under the Act, right cannot be taken away by prescribing time limit through circular. Impugned order rejecting compounding application set aside.
No time limit prescribed u/s 279(2) of Income Tax Act for filing compounding application. CBDT circular fixing 36-month limitation period held contrary to the Act and impermissible. Judgment in Jayshree's case applied, holding CBDT cannot issue circular contrary to the object of statutory provisions. Once an offence is compoundable under the Act, right cannot be taken away by prescribing time limit through circular. Impugned order rejecting compounding application set aside.
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