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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A government communication addresses findings from a performance audit and Public Accounts Committee report highlighting inconsistent treatment of pre-operative expenses in income tax assessments of entertainment sector assessees. It instructs tax authorities to examine expenses segment-wise (e.g., TV, film, events, sports) on a case-by-case basis. Pre-operative expenses must be scrutinized under section 35D of the Income-tax Act. Producers of feature films must file Form 52A with specified details, with possible penalties under section 272A for non-compliance. Expenditure on production and distribution of feature films must be allowed strictly in accordance with Rules 9A and 9B of the Income-tax Rules.
A government communication addresses findings from a performance audit and Public Accounts Committee report highlighting inconsistent treatment of pre-operative expenses in income tax assessments of entertainment sector assessees. It instructs tax authorities to examine expenses segment-wise (e.g., TV, film, events, sports) on a case-by-case basis. Pre-operative expenses must be scrutinized under section 35D of the Income-tax Act. Producers of feature films must file Form 52A with specified details, with possible penalties under section 272A for non-compliance. Expenditure on production and distribution of feature films must be allowed strictly in accordance with Rules 9A and 9B of the Income-tax Rules.
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