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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Review jurisdiction is limited to discovery of new and material evidence, an error apparent on the face of the record, or analogous sufficient reasons; review applications failed as they reargued matters already decided. The Assessing Authority lacked demonstrated competence or procedural fairness to nullify a certificate under the Income Declaration Scheme, 2016, and the declaration - supported by a Registered Valuer and tax payment - was not successfully impugned. Allegations of benami transactions rested on a retracted statement; absent independent corroborative evidence (bank records or transactional proof) provisional attachment could not be sustained. All review petitions dismissed.
Review jurisdiction is limited to discovery of new and material evidence, an error apparent on the face of the record, or analogous sufficient reasons; review applications failed as they reargued matters already decided. The Assessing Authority lacked demonstrated competence or procedural fairness to nullify a certificate under the Income Declaration Scheme, 2016, and the declaration - supported by a Registered Valuer and tax payment - was not successfully impugned. Allegations of benami transactions rested on a retracted statement; absent independent corroborative evidence (bank records or transactional proof) provisional attachment could not be sustained. All review petitions dismissed.
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