Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
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Under Rule 10B, uncontrolled comparables are usable only where material differences do not affect price, cost or profit, or where reasonably accurate adjustments remove their effect. Because the assessee's purchases were largely imported and bore substantial import duty, while the comparables had negligible import content, the duty element materially distorted the resale price method comparison. The Tribunal therefore directed exclusion of import duty from operating cost when computing PLI and ALP, following the Swatch Group principle. It also allowed working capital adjustment, subject to the assessee furnishing necessary details before the TPO. The penalty ground was treated as premature, and the appeal was partly allowed.
Under Rule 10B, uncontrolled comparables are usable only where material differences do not affect price, cost or profit, or where reasonably accurate adjustments remove their effect. Because the assessee's purchases were largely imported and bore substantial import duty, while the comparables had negligible import content, the duty element materially distorted the resale price method comparison. The Tribunal therefore directed exclusion of import duty from operating cost when computing PLI and ALP, following the Swatch Group principle. It also allowed working capital adjustment, subject to the assessee furnishing necessary details before the TPO. The penalty ground was treated as premature, and the appeal was partly allowed.
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