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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Consultancy charges paid to a sister concern were treated as genuine business expenditure because the agreements defined the work, supporting bills were on record, TDS and service tax had been deposited, and no fair market material showed the payment to be excessive; the related-party disallowance was deleted. Interest on vehicle loans was also allowed as business expenditure because the loans related to vehicles acquired in earlier years, part-year interest had been claimed previously, and the current-year increase reflected full-year interest on outstanding borrowings rather than fresh purchases; that disallowance was deleted.
Consultancy charges paid to a sister concern were treated as genuine business expenditure because the agreements defined the work, supporting bills were on record, TDS and service tax had been deposited, and no fair market material showed the payment to be excessive; the related-party disallowance was deleted. Interest on vehicle loans was also allowed as business expenditure because the loans related to vehicles acquired in earlier years, part-year interest had been claimed previously, and the current-year increase reflected full-year interest on outstanding borrowings rather than fresh purchases; that disallowance was deleted.
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