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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Advances written off were held deductible only if the assessee proves they were advanced for business purposes, became irrecoverable, and satisfy the statutory conditions for bad debt or business loss; because complete particulars were not furnished, the matter was remanded for fresh verification. A claim for correct MAT credit carry forward was admitted in principle before the appellate authority, since a new claim may be raised absent a statutory bar, but computation was sent back for scrutiny. An appeal against a rectification order passed in an assessment made under DRP directions was held maintainable. The rectification dispute was also remitted for fresh consideration because proper opportunity was not given and additional evidence required examination.
Advances written off were held deductible only if the assessee proves they were advanced for business purposes, became irrecoverable, and satisfy the statutory conditions for bad debt or business loss; because complete particulars were not furnished, the matter was remanded for fresh verification. A claim for correct MAT credit carry forward was admitted in principle before the appellate authority, since a new claim may be raised absent a statutory bar, but computation was sent back for scrutiny. An appeal against a rectification order passed in an assessment made under DRP directions was held maintainable. The rectification dispute was also remitted for fresh consideration because proper opportunity was not given and additional evidence required examination.
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