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 text addresses revision jurisdiction over income-tax assessments concerning professional and technical fees, sundry creditors, notional interest under Ind AS, and stock valuation. On the alleged difference for professional and technical fees, the record shows AO queries, assessee replies and supporting documents, therefore the revisional finding was contrary to record and unsustainable. On addition of sundry creditors, a debit (trade receivable) was shown and incorporated in P&L, so the revisional addition was factually incorrect and unsustainable. On notional interest, reconciliation with Form 26AS and balance sheet showed no variation, so the revisional action was unwarranted. On stock valuation, AO failed adequate inquiry into valuation method and consistency, so the revisional concern is upheld.
The text addresses revision jurisdiction over income-tax assessments concerning professional and technical fees, sundry creditors, notional interest under Ind AS, and stock valuation. On the alleged difference for professional and technical fees, the record shows AO queries, assessee replies and supporting documents, therefore the revisional finding was contrary to record and unsustainable. On addition of sundry creditors, a debit (trade receivable) was shown and incorporated in P&L, so the revisional addition was factually incorrect and unsustainable. On notional interest, reconciliation with Form 26AS and balance sheet showed no variation, so the revisional action was unwarranted. On stock valuation, AO failed adequate inquiry into valuation method and consistency, so the revisional concern is upheld.
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