Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
In transfer pricing under TNMM, the ITAT treated regular foreign exchange gain as operating income, held that common Delhi and Dehradun expenses had to be allocated on gross profit margins rather than turnover, and applied broad functional comparability to accept the five comparables; it also rejected exclusion of Gontermann Pieper as a persistent loss-maker because it had not suffered losses for three consecutive years. The transfer pricing adjustment was therefore restored to the TPO/AO for recomputation on those terms. On interest deduction, the ITAT applied CIT v. Rajendra Prasad Moody and allowed interest expenditure against interest income, holding that absence of dividend from the subsidiary investment did not justify disallowance. The interest disallowance was deleted.
In transfer pricing under TNMM, the ITAT treated regular foreign exchange gain as operating income, held that common Delhi and Dehradun expenses had to be allocated on gross profit margins rather than turnover, and applied broad functional comparability to accept the five comparables; it also rejected exclusion of Gontermann Pieper as a persistent loss-maker because it had not suffered losses for three consecutive years. The transfer pricing adjustment was therefore restored to the TPO/AO for recomputation on those terms. On interest deduction, the ITAT applied CIT v. Rajendra Prasad Moody and allowed interest expenditure against interest income, holding that absence of dividend from the subsidiary investment did not justify disallowance. The interest disallowance was deleted.
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