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 multiple tax-related issues for the assessee. The tribunal directed the Assessing Officer (AO) to reverify records regarding revised return figures and conduct a fresh assessment. Regarding Section 68 additions, the tribunal found merit in the assessee's arguments about current liabilities and remanded the matter back to the AO for reconsideration. On expense disallowances, the tribunal upheld the CIT(A)'s 5% disallowance, emphasizing the taxpayer's primary responsibility to produce comprehensive evidence supporting expenditure claims. The tribunal's ruling essentially mandates procedural compliance and thorough documentation while providing opportunities for the assessee to substantiate financial representations through proper verification processes.
ITAT adjudicated multiple tax-related issues for the assessee. The tribunal directed the Assessing Officer (AO) to reverify records regarding revised return figures and conduct a fresh assessment. Regarding Section 68 additions, the tribunal found merit in the assessee's arguments about current liabilities and remanded the matter back to the AO for reconsideration. On expense disallowances, the tribunal upheld the CIT(A)'s 5% disallowance, emphasizing the taxpayer's primary responsibility to produce comprehensive evidence supporting expenditure claims. The tribunal's ruling essentially mandates procedural compliance and thorough documentation while providing opportunities for the assessee to substantiate financial representations through proper verification processes.
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