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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The Supreme Court dismissed the civil appeal, affirming the Bombay HC's decision that the assessee validly filed a revised return after discovering the cancellation of five sale agreements involving immovable properties with associate entities. The original return, which included declared income from these transactions, was corrected as no real income had accrued due to the cancellations. The Tribunal's factual findings that the assessee complied with Section 139(5) and that no taxable income arose from the cancelled transactions were upheld. The Court found no reason to interfere with the impugned order, confirming that the revised return accurately reflected the assessee's income position and that hypothetical income could not be taxed.
The Supreme Court dismissed the civil appeal, affirming the Bombay HC's decision that the assessee validly filed a revised return after discovering the cancellation of five sale agreements involving immovable properties with associate entities. The original return, which included declared income from these transactions, was corrected as no real income had accrued due to the cancellations. The Tribunal's factual findings that the assessee complied with Section 139(5) and that no taxable income arose from the cancelled transactions were upheld. The Court found no reason to interfere with the impugned order, confirming that the revised return accurately reflected the assessee's income position and that hypothetical income could not be taxed.
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