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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Receipt characterised as income from house property where transferee of infrastructure business stepped into transferor's position and continued licence payments; licence fees retained the character of rent arising from use of immovable property, so amounts already offered under Income from House Property cannot be subjected to a fresh addition. Assessing Officer must verify the assessee's computation and give effect to the appellate direction to ensure no double addition is made, treating the CNIL receipt as income from house property.
Receipt characterised as income from house property where transferee of infrastructure business stepped into transferor's position and continued licence payments; licence fees retained the character of rent arising from use of immovable property, so amounts already offered under Income from House Property cannot be subjected to a fresh addition. Assessing Officer must verify the assessee's computation and give effect to the appellate direction to ensure no double addition is made, treating the CNIL receipt as income from house property.
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