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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Land located beyond municipal limits (2.75 km per map and Patwari certificate) qualifies as agricultural land under the statutory definition and is therefore not a capital asset; the appellate finding on this classification is accepted. The assessing officer failed to disclose materials underpinning reassessment, denied the assessee opportunity to rebut or examine that material, and rejected the assessee's evidence, amounting to breach of the audi alteram partem principle. Because the land is agricultural, the alleged receipt of additional cash is immaterial. Reassessment additions are set aside and the AO is directed to delete the additions and give effect to this order.
Land located beyond municipal limits (2.75 km per map and Patwari certificate) qualifies as agricultural land under the statutory definition and is therefore not a capital asset; the appellate finding on this classification is accepted. The assessing officer failed to disclose materials underpinning reassessment, denied the assessee opportunity to rebut or examine that material, and rejected the assessee's evidence, amounting to breach of the audi alteram partem principle. Because the land is agricultural, the alleged receipt of additional cash is immaterial. Reassessment additions are set aside and the AO is directed to delete the additions and give effect to this order.
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