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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Section 43D and Rule 6EB form a comprehensive code for deduction on account of non-performing assets (NPAs), distinct from NHB guidelines classifying NPAs. The court held that the tax provisions allow discretion to follow or not follow NHB guidelines when revised. The purpose of NPA classification by NHB differs from non-recognition of income under tax laws. The real income principle is inapplicable to Section 43D deductions, which must satisfy statutory conditions, separate from NHB's prudential norms. The Supreme Court upheld the High Court's decision, dismissing the petition and vacating interim relief granted earlier.
Section 43D and Rule 6EB form a comprehensive code for deduction on account of non-performing assets (NPAs), distinct from NHB guidelines classifying NPAs. The court held that the tax provisions allow discretion to follow or not follow NHB guidelines when revised. The purpose of NPA classification by NHB differs from non-recognition of income under tax laws. The real income principle is inapplicable to Section 43D deductions, which must satisfy statutory conditions, separate from NHB's prudential norms. The Supreme Court upheld the High Court's decision, dismissing the petition and vacating interim relief granted earlier.
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