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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Rejection of books of account in derivative trading was unjustified where the books were audited and detailed trading statements were available; applying a fixed 12% of turnover as an arbitrary profit estimate lacked a reasonable basis. Because the assessing officer did not place material to support either the rejection of accounts or the turnover based estimation, the appellate deletion of the estimated business income was affirmed and the revenue's appeal was dismissed.
Rejection of books of account in derivative trading was unjustified where the books were audited and detailed trading statements were available; applying a fixed 12% of turnover as an arbitrary profit estimate lacked a reasonable basis. Because the assessing officer did not place material to support either the rejection of accounts or the turnover based estimation, the appellate deletion of the estimated business income was affirmed and the revenue's appeal was dismissed.
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