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...
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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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Rule 7B, not the general composite-income rule, governs income from coffee grown and processed by the seller; for self-grown coffee, 40% is taxable as business income and 60% retains agricultural character. The ITAT accepted that the assessee also purchased coffee from other planters and processed and sold it, but Rule 7B did not extend to that purchased coffee in the same manner. The matter was therefore remanded to the Assessing Officer for fresh computation after segregating income from the assessee's own coffee estate from income arising on purchased coffee, with agricultural exemption available only to the self-grown produce.
Rule 7B, not the general composite-income rule, governs income from coffee grown and processed by the seller; for self-grown coffee, 40% is taxable as business income and 60% retains agricultural character. The ITAT accepted that the assessee also purchased coffee from other planters and processed and sold it, but Rule 7B did not extend to that purchased coffee in the same manner. The matter was therefore remanded to the Assessing Officer for fresh computation after segregating income from the assessee's own coffee estate from income arising on purchased coffee, with agricultural exemption available only to the self-grown produce.
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