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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Payments made by a sister concern towards software testing and development, and adjusted against the assessee's business bills, were held not to constitute deemed dividend. The Court relied on concurrent factual findings that the transactions arose in the regular course of business, and the Revenue failed to rebut that position. Trade advances and commercial payments that are neither loans nor advances within the meaning of the provision fall outside deemed dividend treatment under section 2(22)(e). The questions of law were answered in favour of the assessee and the Revenue's appeal was dismissed.
Payments made by a sister concern towards software testing and development, and adjusted against the assessee's business bills, were held not to constitute deemed dividend. The Court relied on concurrent factual findings that the transactions arose in the regular course of business, and the Revenue failed to rebut that position. Trade advances and commercial payments that are neither loans nor advances within the meaning of the provision fall outside deemed dividend treatment under section 2(22)(e). The questions of law were answered in favour of the assessee and the Revenue's appeal was dismissed.
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