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...
Quantification of weighted deduction under section 35(2AB) depended on the expenditure approved in Form 3CL, not on the assessee's basic eligibility for the deduction. The Tribunal held that Form 3CL had already been sent to the jurisdictional Assessing Officer and therefore could not be rejected as additional evidence in rectification proceedings. Reading Rule 6(7A) for the relevant assessment year, the Assessing Officer was required to take cognizance of the approved expenditure and recompute the deduction accordingly. The impugned order was set aside and the issue was restored for fresh quantification after giving the assessee a reasonable opportunity of hearing.
Quantification of weighted deduction under section 35(2AB) depended on the expenditure approved in Form 3CL, not on the assessee's basic eligibility for the deduction. The Tribunal held that Form 3CL had already been sent to the jurisdictional Assessing Officer and therefore could not be rejected as additional evidence in rectification proceedings. Reading Rule 6(7A) for the relevant assessment year, the Assessing Officer was required to take cognizance of the approved expenditure and recompute the deduction accordingly. The impugned order was set aside and the issue was restored for fresh quantification after giving the assessee a reasonable opportunity of hearing.
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