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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Article discusses validity of an income tax assessment and penalty under section 271AAD(1)(i), emphasising that assessments rest on a preponderance of probabilities and are sustained if that standard is met. It notes the assessee failed to obtain or request copies of seized materials forming the basis of the assessment and belatedly sought unnamed cross examination, which the author treats as insufficient to vitiate the process. While writ petitions seeking relief lack merit on those grounds, the impugned orders were quashed and the matter remitted with an opportunity for the assessee to apply for relevant documents and file fresh replies.
Article discusses validity of an income tax assessment and penalty under section 271AAD(1)(i), emphasising that assessments rest on a preponderance of probabilities and are sustained if that standard is met. It notes the assessee failed to obtain or request copies of seized materials forming the basis of the assessment and belatedly sought unnamed cross examination, which the author treats as insufficient to vitiate the process. While writ petitions seeking relief lack merit on those grounds, the impugned orders were quashed and the matter remitted with an opportunity for the assessee to apply for relevant documents and file fresh replies.
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