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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Presumption as to ownership of seized material does not permit altering recorded figures in seized documents without independent corroboration; speculative reconstruction of numeric entries (adding two zeros) is inadmissible and additions under unexplained investment and consequential interest founded solely on that hypothesis are deleted. Entries on loose sheets described as estimates likewise lack corroboration and cannot support additions, and a retracted statement under seizure has no standalone evidentiary value. Result: deletions of additions based on speculative diary alteration and uncorroborated loose-sheet entries; ownership of the diary acknowledged but cannot substitute for independent proof.
Presumption as to ownership of seized material does not permit altering recorded figures in seized documents without independent corroboration; speculative reconstruction of numeric entries (adding two zeros) is inadmissible and additions under unexplained investment and consequential interest founded solely on that hypothesis are deleted. Entries on loose sheets described as estimates likewise lack corroboration and cannot support additions, and a retracted statement under seizure has no standalone evidentiary value. Result: deletions of additions based on speculative diary alteration and uncorroborated loose-sheet entries; ownership of the diary acknowledged but cannot substitute for independent proof.
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