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 dismissed revision petition under Section 264 challenging addition to total income for stock shortage discovered during Central Excise survey. Assessee contended only gross profit should be added, not entire shortage amount. Court upheld Revisional Authority's finding that assessee failed to provide satisfactory explanation for discrepancy during assessment or penalty proceedings. Assessee had accepted stock shortage as sales outside books and paid excise duty accordingly. Since raw material costs were already accounted in regular books, entire off-books sales constituted taxable income requiring full addition. Court noted penalty proceedings under Section 271(1)(c) remain separate from assessment proceedings, rendering revision petition ineffective for appellate relief against penalty.
HC dismissed revision petition under Section 264 challenging addition to total income for stock shortage discovered during Central Excise survey. Assessee contended only gross profit should be added, not entire shortage amount. Court upheld Revisional Authority's finding that assessee failed to provide satisfactory explanation for discrepancy during assessment or penalty proceedings. Assessee had accepted stock shortage as sales outside books and paid excise duty accordingly. Since raw material costs were already accounted in regular books, entire off-books sales constituted taxable income requiring full addition. Court noted penalty proceedings under Section 271(1)(c) remain separate from assessment proceedings, rendering revision petition ineffective for appellate relief against penalty.
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