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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HC allowed the writ petition challenging Commissioner's order under Section 264. Prior amendment of Return of Income was not mandatory before filing revision application. Commissioner failed to consider DTAA provisions and "make available" clause for determining royalty payments. Following Vijay Gupta and Interglobe Enterprises precedents, Court held that taxpayers can rectify earlier mistaken positions through Section 264, even for suo moto disallowances made under incorrect interpretation. Tax liability exists only for income chargeable under the Act. Commissioner directed to reconsider revision application examining DTAA implications and royalty characterization afresh, particularly the "make available" condition.
HC allowed the writ petition challenging Commissioner's order under Section 264. Prior amendment of Return of Income was not mandatory before filing revision application. Commissioner failed to consider DTAA provisions and "make available" clause for determining royalty payments. Following Vijay Gupta and Interglobe Enterprises precedents, Court held that taxpayers can rectify earlier mistaken positions through Section 264, even for suo moto disallowances made under incorrect interpretation. Tax liability exists only for income chargeable under the Act. Commissioner directed to reconsider revision application examining DTAA implications and royalty characterization afresh, particularly the "make available" condition.
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