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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The note addresses valuation and disallowance issues: an allotment letter accompanied by part payment through prescribed banking channels can constitute the agreement fixing consideration for comparing actual sale consideration with Stamp Duty Valuation, and the tax authority was directed to verify receipt dates and compare SDV as of allotment; separate disallowances under the rule limiting deduction for exempt-income-related expenditure are unsustainable where no exempt income was earned, and similar 14A additions cannot be made in computing book profit, leading to deletions of those adjustments and remittance of the 43CA factual verification to the assessing officer.
The note addresses valuation and disallowance issues: an allotment letter accompanied by part payment through prescribed banking channels can constitute the agreement fixing consideration for comparing actual sale consideration with Stamp Duty Valuation, and the tax authority was directed to verify receipt dates and compare SDV as of allotment; separate disallowances under the rule limiting deduction for exempt-income-related expenditure are unsustainable where no exempt income was earned, and similar 14A additions cannot be made in computing book profit, leading to deletions of those adjustments and remittance of the 43CA factual verification to the assessing officer.
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