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 addressed differential turnover where assessee declared lower turnover compared to Form 26QB and audit report Form 3CA. AO added entire differential amount to total income. CIT(A) restricted addition to profit element at 15% of differential receipts. ITAT held that since assessee's P&L Account reflected net material consumption considering opening/closing work-in-progress, entire differential amount cannot constitute income. Given assessee's declared gross profit rate of 16.22%, ITAT modified CIT(A)'s order directing AO to compute income using 16.22% gross profit rate instead of 15%. Revenue's appeal partly allowed with profit computation adjusted to reflect assessee's actual gross profit margin rather than CIT(A)'s conservative estimate.
ITAT addressed differential turnover where assessee declared lower turnover compared to Form 26QB and audit report Form 3CA. AO added entire differential amount to total income. CIT(A) restricted addition to profit element at 15% of differential receipts. ITAT held that since assessee's P&L Account reflected net material consumption considering opening/closing work-in-progress, entire differential amount cannot constitute income. Given assessee's declared gross profit rate of 16.22%, ITAT modified CIT(A)'s order directing AO to compute income using 16.22% gross profit rate instead of 15%. Revenue's appeal partly allowed with profit computation adjusted to reflect assessee's actual gross profit margin rather than CIT(A)'s conservative estimate.
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