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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AT partly allowed the appeal and directed the respondent to permit inspection and production of investigatory material to the appellant to the extent necessary to test the charges. The respondent must provide the chats between the appellant and any entity, copies of statements of fund managers, documents seized from the appellant's desk, the daily register maintained by the asset manager, and the appellant's trade logs and the Big Client's trade details limited to scrip, quantum and time of order placement. Entire third-party chats may be withheld to protect privacy. The respondent's reliance on call data records was rejected and the appellant is entitled to his call details. No direction is given concerning production of a Section 65B certificate.
AT partly allowed the appeal and directed the respondent to permit inspection and production of investigatory material to the appellant to the extent necessary to test the charges. The respondent must provide the chats between the appellant and any entity, copies of statements of fund managers, documents seized from the appellant's desk, the daily register maintained by the asset manager, and the appellant's trade logs and the Big Client's trade details limited to scrip, quantum and time of order placement. Entire third-party chats may be withheld to protect privacy. The respondent's reliance on call data records was rejected and the appellant is entitled to his call details. No direction is given concerning production of a Section 65B certificate.
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