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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Assessment of trust expenditure centred on whether claimed expenses demonstrated application of income for charitable purposes; the tribunal accepted documentary evidence (salary registers, salary ledgers, cash book, bank book, payment records and other ledger accounts) and agreed with the CIT(A) that the assessing officer offered no basis to disallow a portion of expenses. The appellate panel found the majority of costs were salary-related and substantiated, noted no infirmity in the remaining ledgers, and dismissed the revenue appeal for lack of contrary evidential foundation.
Assessment of trust expenditure centred on whether claimed expenses demonstrated application of income for charitable purposes; the tribunal accepted documentary evidence (salary registers, salary ledgers, cash book, bank book, payment records and other ledger accounts) and agreed with the CIT(A) that the assessing officer offered no basis to disallow a portion of expenses. The appellate panel found the majority of costs were salary-related and substantiated, noted no infirmity in the remaining ledgers, and dismissed the revenue appeal for lack of contrary evidential foundation.
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