Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
Customs Broker licence proceedings require accurate procedural facts before delay or natural-justice findings can justify setting aside regulatory act...
Under TNMM, comparability must reflect functional, asset and risk differences, and idle capacity in a start-up ramp-up phase may require adjustment where it distorts net margins. The assessee showed its first full-fledged year of operations, a clear operational ramp-up, improved cost absorption in the next year, and a transparent methodology for the claim; the idle capacity adjustment was therefore allowed in the EPC segment. Working capital adjustment must likewise follow the tested party's actual operating cycle, including relevant operating current assets and liabilities and excluding only non-operating or financial items. Unbilled revenue and material prepayments or advances were treated as operating items, and fresh recomputation was directed subject to verification.
Under TNMM, comparability must reflect functional, asset and risk differences, and idle capacity in a start-up ramp-up phase may require adjustment where it distorts net margins. The assessee showed its first full-fledged year of operations, a clear operational ramp-up, improved cost absorption in the next year, and a transparent methodology for the claim; the idle capacity adjustment was therefore allowed in the EPC segment. Working capital adjustment must likewise follow the tested party's actual operating cycle, including relevant operating current assets and liabilities and excluding only non-operating or financial items. Unbilled revenue and material prepayments or advances were treated as operating items, and fresh recomputation was directed subject to verification.
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