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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Belated filing of Form 10CCB did not, by itself, justify denial of deduction under section 80IA where the return was filed in time and the audit report was on record before processing under section 143(1). The Tribunal held that filing Form 10CCB by the due date is a procedural requirement, and once the report was furnished before issuance of the intimation, the CPC was bound to examine it. On that basis, the Commissioner (Appeals)' order allowing the deduction was upheld and the Revenue's challenge to the disallowance failed.
Belated filing of Form 10CCB did not, by itself, justify denial of deduction under section 80IA where the return was filed in time and the audit report was on record before processing under section 143(1). The Tribunal held that filing Form 10CCB by the due date is a procedural requirement, and once the report was furnished before issuance of the intimation, the CPC was bound to examine it. On that basis, the Commissioner (Appeals)' order allowing the deduction was upheld and the Revenue's challenge to the disallowance failed.
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