Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Transfer pricing comparability adjustments were examined on foreign exchange fluctuation, customs duty, price penetration, liability write-back, and capacity utilisation. Consistent treatment of foreign exchange movement as non-operating in earlier and later years led to remand for fresh consideration. Customs duty and price penetration adjustment claims were also remitted because the factual basis and supporting details were not adequately examined. Liability write-back was treated as operating income where the underlying trade payables related to operating expenses, while other breakup items required verification. For capacity utilisation, the Tribunal rejected a depreciation-to-sales adjustment method as not reasonably accurate, but directed recomputation of ALP using cash PLI for the assessee and comparables.
Transfer pricing comparability adjustments were examined on foreign exchange fluctuation, customs duty, price penetration, liability write-back, and capacity utilisation. Consistent treatment of foreign exchange movement as non-operating in earlier and later years led to remand for fresh consideration. Customs duty and price penetration adjustment claims were also remitted because the factual basis and supporting details were not adequately examined. Liability write-back was treated as operating income where the underlying trade payables related to operating expenses, while other breakup items required verification. For capacity utilisation, the Tribunal rejected a depreciation-to-sales adjustment method as not reasonably accurate, but directed recomputation of ALP using cash PLI for the assessee and comparables.
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