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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Telescoping was accepted on the basis of surplus funds from earlier assessment years, so the sustained additions for shortage of funds in AY 2000-01 and for undisclosed income and vehicle investment in AY 2002-03 did not survive. For AY 2002-03, the capital gains addition was confined to the assessee's own computation because the higher figure in the appellate order was treated as an inadvertent error. The deduction claim under section 54 was rejected for want of substantiation.
Telescoping was accepted on the basis of surplus funds from earlier assessment years, so the sustained additions for shortage of funds in AY 2000-01 and for undisclosed income and vehicle investment in AY 2002-03 did not survive. For AY 2002-03, the capital gains addition was confined to the assessee's own computation because the higher figure in the appellate order was treated as an inadvertent error. The deduction claim under section 54 was rejected for want of substantiation.
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