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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Dispute concerned additions to income under section 68 and section 56(2)(viib) alleging unexplained large share capital and excessive premium. Tribunal found that notices to lenders were duly issued and acknowledged and that lenders filed confirmations, so the file contained materials establishing the genuineness, identity and creditworthiness of creditors; this factual appreciation led to dismissal of the revenue's appeal. Non-appearance of directors under summons was noted but did not negate the documentary evidence confirming transactions.
Dispute concerned additions to income under section 68 and section 56(2)(viib) alleging unexplained large share capital and excessive premium. Tribunal found that notices to lenders were duly issued and acknowledged and that lenders filed confirmations, so the file contained materials establishing the genuineness, identity and creditworthiness of creditors; this factual appreciation led to dismissal of the revenue's appeal. Non-appearance of directors under summons was noted but did not negate the documentary evidence confirming transactions.
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