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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Validity of valuation u/s 56(2)(viib) was questioned. The Assessing Officer rejected the assessee's valuation report and framed the order based on actual figures, which was criticized by the CIT(A) and ITAT. The High Court observed that an estimation would be based on approximate evaluation and should not be questioned based on actual facts or figures. The correctness of an estimation should be tested on legitimate and valid assessment. While upholding the ITAT's view, the High Court remitted the matter to the Assessing Officer to undertake valuation afresh considering Section 56(2)(viib), adhering to the DCF Method. If the assessee's data warrants examination, the Assessing Officer can enlist an appropriate valuer's services.
Validity of valuation u/s 56(2)(viib) was questioned. The Assessing Officer rejected the assessee's valuation report and framed the order based on actual figures, which was criticized by the CIT(A) and ITAT. The High Court observed that an estimation would be based on approximate evaluation and should not be questioned based on actual facts or figures. The correctness of an estimation should be tested on legitimate and valid assessment. While upholding the ITAT's view, the High Court remitted the matter to the Assessing Officer to undertake valuation afresh considering Section 56(2)(viib), adhering to the DCF Method. If the assessee's data warrants examination, the Assessing Officer can enlist an appropriate valuer's services.
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