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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Nature of expenditure - the amount paid by assessee to ITC Limited at the time of termination of the agreement to manage the hotel, ought to be allowed, as a revenue expenditure or entitlement to depreciation @10 % as building - if the expenditure is not to be treated as ‘capital expenditure’, then it will have to be treated as ‘revenue expenditure’ was perhaps not addressed in the manner it should have been treated by the ITAT - remanded to ITAT
Nature of expenditure - the amount paid by assessee to ITC Limited at the time of termination of the agreement to manage the hotel, ought to be allowed, as a revenue expenditure or entitlement to depreciation @10 % as building - if the expenditure is not to be treated as ‘capital expenditure’, then it will have to be treated as ‘revenue expenditure’ was perhaps not addressed in the manner it should have been treated by the ITAT - remanded to ITAT
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