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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Assessee successfully met the initial burden to prove identity, creditworthiness and genuineness of unexplained cash credits from an investor company; the AO failed to make independent enquiries or produce contrary material, so additions under section 68 were deleted. Assessee's claim of agricultural income, previously accepted in an earlier year and supported by ownership of agricultural land, was held genuine and the related addition was deleted. Assessee also satisfied factual conditions for long term capital gains by acquiring shares through preferential allotment, paying by account payee cheques, holding for requisite period and selling on a recognised stock exchange with STT paid; denial of section 10(38) benefit was reversed.
Assessee successfully met the initial burden to prove identity, creditworthiness and genuineness of unexplained cash credits from an investor company; the AO failed to make independent enquiries or produce contrary material, so additions under section 68 were deleted. Assessee's claim of agricultural income, previously accepted in an earlier year and supported by ownership of agricultural land, was held genuine and the related addition was deleted. Assessee also satisfied factual conditions for long term capital gains by acquiring shares through preferential allotment, paying by account payee cheques, holding for requisite period and selling on a recognised stock exchange with STT paid; denial of section 10(38) benefit was reversed.
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