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 HC upheld the validity of document retention under section 133A during a survey, rejecting the petitioners' claim for return of impounded materials, as no physical books of account were seized. The court confirmed the petitioners' entitlement to certified copies of seized documents upon payment. Subsequent assessment orders were completed and upheld by the ITAT, rendering the writ petition infructuous. The court found the petitioners failed to substantiate share application money, relying on inadmissible loose papers, with findings corroborated by the Assessing Officer, CIT, and ITAT. The petitioners did not challenge compliance with orders to supply seized documents, negating claims of procedural irregularity. The HC distinguished survey from search operations, ruling that provisions under sections 153A-D apply only to searches, not surveys. Consequently, all contested questions were decided against the petitioners, affirming the legality of the survey and related assessment proceedings.
The HC upheld the validity of document retention under section 133A during a survey, rejecting the petitioners' claim for return of impounded materials, as no physical books of account were seized. The court confirmed the petitioners' entitlement to certified copies of seized documents upon payment. Subsequent assessment orders were completed and upheld by the ITAT, rendering the writ petition infructuous. The court found the petitioners failed to substantiate share application money, relying on inadmissible loose papers, with findings corroborated by the Assessing Officer, CIT, and ITAT. The petitioners did not challenge compliance with orders to supply seized documents, negating claims of procedural irregularity. The HC distinguished survey from search operations, ruling that provisions under sections 153A-D apply only to searches, not surveys. Consequently, all contested questions were decided against the petitioners, affirming the legality of the survey and related assessment proceedings.
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