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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ITAT adjudicated a tax dispute involving unaccounted cash receipts and deemed dividend. The tribunal directed the Assessing Officer to allow 60% of expenditure against unaccounted cash receipts from sale of spent solvents/scrap, sustaining 40% addition. Following precedent in MSN Pharmachem Private Limited's case, the tribunal deleted the addition under Section 2(22)(e) of the Income Tax Act related to deemed dividend, thereby dismissing the Revenue's appeal and providing partial relief to the assessee.
ITAT adjudicated a tax dispute involving unaccounted cash receipts and deemed dividend. The tribunal directed the Assessing Officer to allow 60% of expenditure against unaccounted cash receipts from sale of spent solvents/scrap, sustaining 40% addition. Following precedent in MSN Pharmachem Private Limited's case, the tribunal deleted the addition under Section 2(22)(e) of the Income Tax Act related to deemed dividend, thereby dismissing the Revenue's appeal and providing partial relief to the assessee.
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