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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Claim of expenditure against interest Income - Since, we hold in principle that the expenditure is allowable either way u/s 57, if the income is treated under the head “income from other sources” as per the provisions of Section 56 or u/s 37, if the income is treated under the head “profits and gains of business or profession” as per the provisions of Section 28, at this juncture, we refrain from determining issue of the claim of preclusion or collateral estoppel under “which head” the income earned by the assessee is taxable. - AT
Claim of expenditure against interest Income - Since, we hold in principle that the expenditure is allowable either way u/s 57, if the income is treated under the head “income from other sources” as per the provisions of Section 56 or u/s 37, if the income is treated under the head “profits and gains of business or profession” as per the provisions of Section 28, at this juncture, we refrain from determining issue of the claim of preclusion or collateral estoppel under “which head” the income earned by the assessee is taxable. - AT
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