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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CIT(A) determined excess stock and short stock during survey. ITAT partly allowed assessee's appeal. For excess stock, benefit of doubt given to assessee for 50% of value. For short stock, ITAT directed AO to adopt 12.72% gross profit rate instead of 25% adopted by CIT(A). Appeal partly allowed.
CIT(A) determined excess stock and short stock during survey. ITAT partly allowed assessee's appeal. For excess stock, benefit of doubt given to assessee for 50% of value. For short stock, ITAT directed AO to adopt 12.72% gross profit rate instead of 25% adopted by CIT(A). Appeal partly allowed.
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