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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Deduction u/s 80IC - Since in the present case the fact that the assessee had undertaken substantial expansion is not disputed, the assessee, we hold, is entitled to claim deduction @ 100% of its eligible profits for five years from the initial year of substantial expansion even though the assessee has already claimed deduction of the profits at the rate of 100% for first five years subject to the condition that the total period of deduction u/s 80IC will not exceed 10 years from the initial year of commencement of unit
Deduction u/s 80IC - Since in the present case the fact that the assessee had undertaken substantial expansion is not disputed, the assessee, we hold, is entitled to claim deduction @ 100% of its eligible profits for five years from the initial year of substantial expansion even though the assessee has already claimed deduction of the profits at the rate of 100% for first five years subject to the condition that the total period of deduction u/s 80IC will not exceed 10 years from the initial year of commencement of unit
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