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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Rental income from leased properties consistently assessed as income from house property in prior and subsequent years. Sale of some properties in relevant years incidental to core activity of letting out properties, cannot change nature of income to business income. Income from sale of properties assessable as capital gains, not business income. Appellate Tribunal lacked jurisdiction to entertain belated rectification applications filed by Revenue beyond statutory six-month period. Allowing such applications after earlier dismissal of appeals citing low tax effect, either amounted to impermissible review or exceeded rectification powers, rendering Tribunal's orders void ab initio. Decided against Revenue.
Rental income from leased properties consistently assessed as income from house property in prior and subsequent years. Sale of some properties in relevant years incidental to core activity of letting out properties, cannot change nature of income to business income. Income from sale of properties assessable as capital gains, not business income. Appellate Tribunal lacked jurisdiction to entertain belated rectification applications filed by Revenue beyond statutory six-month period. Allowing such applications after earlier dismissal of appeals citing low tax effect, either amounted to impermissible review or exceeded rectification powers, rendering Tribunal's orders void ab initio. Decided against Revenue.
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