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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Capital gains on a slump sale under section 50B were recomputed to allow reduction of capital work-in-progress that had been inadvertently omitted from the original working. The Tribunal noted that the assessee had already offered the slump sale gain in the original return, explained the omission during assessment, and showed the asset consistently in earlier balance sheets. As the Assessing Officer rejected the claim only because it was not made through a revised return, without disputing its factual correctness or adducing contrary material, the correction could not be denied on that procedural ground. The appellate order allowing the recomputation was upheld.
Capital gains on a slump sale under section 50B were recomputed to allow reduction of capital work-in-progress that had been inadvertently omitted from the original working. The Tribunal noted that the assessee had already offered the slump sale gain in the original return, explained the omission during assessment, and showed the asset consistently in earlier balance sheets. As the Assessing Officer rejected the claim only because it was not made through a revised return, without disputing its factual correctness or adducing contrary material, the correction could not be denied on that procedural ground. The appellate order allowing the recomputation was upheld.
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