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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Assessing Officer's suo motu computation of net profit based solely on a survey statement without rejecting books or affording explanation was held arbitrary and the addition deleted. Alleged deemed sales of four parking spaces lacked contemporaneous stock records; Tribunal remitted the matter for fresh verification and afforded the assessee a hearing. Interest on unsecured loans capitalised as part of Work in Progress for a real estate developer was treated as business expenditure (acquisition/holding of land as inventory) and the AO's disallowance of such capitalised interest was reversed.
Assessing Officer's suo motu computation of net profit based solely on a survey statement without rejecting books or affording explanation was held arbitrary and the addition deleted. Alleged deemed sales of four parking spaces lacked contemporaneous stock records; Tribunal remitted the matter for fresh verification and afforded the assessee a hearing. Interest on unsecured loans capitalised as part of Work in Progress for a real estate developer was treated as business expenditure (acquisition/holding of land as inventory) and the AO's disallowance of such capitalised interest was reversed.
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