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 quashed Tribunal's order regarding reopening of assessment based on alleged non-disclosure of unabsorbed investment allowance. The Tribunal erroneously concluded that depreciation claims for trial production machinery weren't shown in computation statements, despite no such requirement existing. Examining orders under s.143(3) and reassessment order dated 29.10.1999, AO had thoroughly considered depreciation based on complete disclosure by assessee. Finding no failure in true and full disclosure of material facts, HC deemed Tribunal's rejection of Misc. Application perverse. Matter remanded to Tribunal for fresh de-novo order, with assessee's Misc. Application allowed.
HC quashed Tribunal's order regarding reopening of assessment based on alleged non-disclosure of unabsorbed investment allowance. The Tribunal erroneously concluded that depreciation claims for trial production machinery weren't shown in computation statements, despite no such requirement existing. Examining orders under s.143(3) and reassessment order dated 29.10.1999, AO had thoroughly considered depreciation based on complete disclosure by assessee. Finding no failure in true and full disclosure of material facts, HC deemed Tribunal's rejection of Misc. Application perverse. Matter remanded to Tribunal for fresh de-novo order, with assessee's Misc. Application allowed.
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