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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Addition for revaluation of closing stock was contested on the ground that the assessee had previously provided for diminution in value of old/damaged stock and revalued closing stock for the year with a quantified reduction of Rs. 26,88,599, not the higher figure estimated by the AO; the Tribunal accepted the lower figure. The Tribunal found the valuation procedure-branch head physical verification, Director of Societies supervision, auditor approval-scientific and reasonable and, since audited books were not rejected under Section 145(3), held the AO's addition on stock valuation unjustified.
Addition for revaluation of closing stock was contested on the ground that the assessee had previously provided for diminution in value of old/damaged stock and revalued closing stock for the year with a quantified reduction of Rs. 26,88,599, not the higher figure estimated by the AO; the Tribunal accepted the lower figure. The Tribunal found the valuation procedure-branch head physical verification, Director of Societies supervision, auditor approval-scientific and reasonable and, since audited books were not rejected under Section 145(3), held the AO's addition on stock valuation unjustified.
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