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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Best-judgment assessment of security agency service value must rest on actual, verifiable records and a rational nexus to services and consideration, rather than assumed growth or earlier peak turnover; unsupported demands require fresh determination. Receipts must be examined transaction-wise to exclude legally exempt, non-taxable and genuine reimbursable amounts, subject after amendment to pure-agent conditions. Export and SEZ exemptions require examination of transactional evidence, not rejection solely for missing documents. CENVAT credit cannot be denied merely because salary expenditure predominates; admissibility requires record-based verification. Extended limitation requires deliberate evasion and is unavailable for disclosed audited records, subject in any event to the five-year outer limit. Parallel proceedings must not produce duplicate demand or recovery; remand must exclude transactions already determined.
Best-judgment assessment of security agency service value must rest on actual, verifiable records and a rational nexus to services and consideration, rather than assumed growth or earlier peak turnover; unsupported demands require fresh determination. Receipts must be examined transaction-wise to exclude legally exempt, non-taxable and genuine reimbursable amounts, subject after amendment to pure-agent conditions. Export and SEZ exemptions require examination of transactional evidence, not rejection solely for missing documents. CENVAT credit cannot be denied merely because salary expenditure predominates; admissibility requires record-based verification. Extended limitation requires deliberate evasion and is unavailable for disclosed audited records, subject in any event to the five-year outer limit. Parallel proceedings must not produce duplicate demand or recovery; remand must exclude transactions already determined.
Note: It is a system-generated summary and is for quick reference only.