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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Under the faceless assessment framework, specialized units (Assessment, Verification, Technical, Review) must conduct or procure factual verification when complex technical claims arise. The Principal Commissioner found the assessment silent on actuarial valuation of post employment benefit remeasurement, payments vis a vis tax deductibility rules, and adjustments for realized foreign exchange gains to capital assets, with no Verification Unit report or recorded enquiries. That absence amounted to a lack of enquiry rather than mere inadequate enquiry; consequence: the assessment was set aside and the Assessing Officer directed to carry out proper verification and pass a fresh order after allowing the taxpayer opportunity to be heard.
Under the faceless assessment framework, specialized units (Assessment, Verification, Technical, Review) must conduct or procure factual verification when complex technical claims arise. The Principal Commissioner found the assessment silent on actuarial valuation of post employment benefit remeasurement, payments vis a vis tax deductibility rules, and adjustments for realized foreign exchange gains to capital assets, with no Verification Unit report or recorded enquiries. That absence amounted to a lack of enquiry rather than mere inadequate enquiry; consequence: the assessment was set aside and the Assessing Officer directed to carry out proper verification and pass a fresh order after allowing the taxpayer opportunity to be heard.
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