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 of employees' provident fund contribution was upheld following binding precedent; consequence: contribution remains disallowed for tax purposes. Provision for leave encashment computed actuarially was held to be an ascertained business liability and allowable as a deduction. Deduction under section 80G for CSR-linked donations was permitted where payments lacked quid pro quo, preventing double disallowance. Claims for DDT credit and interest were remitted to the Assessing Officer for factual verification and record scrutiny. Year end ad hoc expense provision reversed in a subsequent year was allowed as a deduction. Additions for short term capital gains and late deposited contributions were ordered verified and deleted if shown to be factually incorrect.
Disallowance of employees' provident fund contribution was upheld following binding precedent; consequence: contribution remains disallowed for tax purposes. Provision for leave encashment computed actuarially was held to be an ascertained business liability and allowable as a deduction. Deduction under section 80G for CSR-linked donations was permitted where payments lacked quid pro quo, preventing double disallowance. Claims for DDT credit and interest were remitted to the Assessing Officer for factual verification and record scrutiny. Year end ad hoc expense provision reversed in a subsequent year was allowed as a deduction. Additions for short term capital gains and late deposited contributions were ordered verified and deleted if shown to be factually incorrect.
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