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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Tribunal applied Coordinate Bench precedents to permit revised characterisation of investment sale proceeds as capital gains and to allow exemption for long term listed equity gains where the taxpayer chose that treatment; it allowed rent equalisation as a timing difference deduction and upheld allowability of insurance specific provisions including IBNR/IBNER and reinsurance premium deductions. The Tribunal set aside reversal of reserve for unexpired risks to the assessing officer for verification and compliance with Rule 6E conditions, and remitted recomputation and verification of interest to the assessing officer for recalculation in accordance with law.
Tribunal applied Coordinate Bench precedents to permit revised characterisation of investment sale proceeds as capital gains and to allow exemption for long term listed equity gains where the taxpayer chose that treatment; it allowed rent equalisation as a timing difference deduction and upheld allowability of insurance specific provisions including IBNR/IBNER and reinsurance premium deductions. The Tribunal set aside reversal of reserve for unexpired risks to the assessing officer for verification and compliance with Rule 6E conditions, and remitted recomputation and verification of interest to the assessing officer for recalculation in accordance with law.
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