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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Assessment u/s 153C - disallowance made u/s 37. Assessing Officer observed no supporting evidence for claimed expenses furnished by assessee and non-cooperation during search and post-search inquiries. Held: Expenses other than accommodation charges under 'Administrative Expenses', 'Business Promotion Expenses' and 'Tour & Travel Expenses' under 'Selling and Distribution Expenses' are routine and acceptable. Salary income received from assessee company offered, disallowance of depreciation and interest on late TDS deposit debited in P&L not justified. Claim of expenses partly acceptable as per CIT(A) decision. No evidence other than ledger accounts for accommodation, promotion, and travel expenses. Reasonable disallowance of Rs. 15 lakhs estimated considering assessee's offered disallowance of Rs. 9 lakhs from total Rs. 42,42,974 expenses. Proceedings u/s 153C upheld based on Nau Nidh Overseas Pvt. Ltd. case. Revenue appeal partly allowed.
Assessment u/s 153C - disallowance made u/s 37. Assessing Officer observed no supporting evidence for claimed expenses furnished by assessee and non-cooperation during search and post-search inquiries. Held: Expenses other than accommodation charges under 'Administrative Expenses', 'Business Promotion Expenses' and 'Tour & Travel Expenses' under 'Selling and Distribution Expenses' are routine and acceptable. Salary income received from assessee company offered, disallowance of depreciation and interest on late TDS deposit debited in P&L not justified. Claim of expenses partly acceptable as per CIT(A) decision. No evidence other than ledger accounts for accommodation, promotion, and travel expenses. Reasonable disallowance of Rs. 15 lakhs estimated considering assessee's offered disallowance of Rs. 9 lakhs from total Rs. 42,42,974 expenses. Proceedings u/s 153C upheld based on Nau Nidh Overseas Pvt. Ltd. case. Revenue appeal partly allowed.
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