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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Profit on sale of fixed assets was required to be routed through the profit and loss account for computation of book profit under section 115JB, because Part II of Schedule VI requires disclosure of material receipts and exceptional transactions in the accounts. Direct credit of such capital profit to reserves and surplus was treated as an impermissible deviation from the prescribed accounting format, particularly where no justifiable reason for the departure was shown. Relying on Supreme Court authority, the Court affirmed that the company must prepare its accounts strictly in accordance with Schedule VI for MAT purposes and upheld reworking of book profits accordingly.
Profit on sale of fixed assets was required to be routed through the profit and loss account for computation of book profit under section 115JB, because Part II of Schedule VI requires disclosure of material receipts and exceptional transactions in the accounts. Direct credit of such capital profit to reserves and surplus was treated as an impermissible deviation from the prescribed accounting format, particularly where no justifiable reason for the departure was shown. Relying on Supreme Court authority, the Court affirmed that the company must prepare its accounts strictly in accordance with Schedule VI for MAT purposes and upheld reworking of book profits accordingly.
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