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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Disallowance arose over a gratuity expense claimed where one transferred employee's gratuity liability was moved to a related concern. Tribunal reasoned that transferring the liability to the other concern constituted discharge of the assessee's obligation akin to actual payment, because the employee had rendered services to the assessee and the liability was validly shifted; accordingly the gratuity expense was allowable and the appeal was allowed by the ITAT.
Disallowance arose over a gratuity expense claimed where one transferred employee's gratuity liability was moved to a related concern. Tribunal reasoned that transferring the liability to the other concern constituted discharge of the assessee's obligation akin to actual payment, because the employee had rendered services to the assessee and the liability was validly shifted; accordingly the gratuity expense was allowable and the appeal was allowed by the ITAT.
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