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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Disallowance of Capital Expenditure written off - CIT-A had given a categorical finding that Capital expenditure incurred by the assessee was not doubted by the ld AO, said expenditure was incurred for the purpose of extension of project was not doubted by the ld AO and said extension project has been given up by the assessee and hence the asset generated thereon is not in use. These factual observations were not controverted by the revenue before us. - Order of CIT(A) confirmed - AT
Disallowance of Capital Expenditure written off - CIT-A had given a categorical finding that Capital expenditure incurred by the assessee was not doubted by the ld AO, said expenditure was incurred for the purpose of extension of project was not doubted by the ld AO and said extension project has been given up by the assessee and hence the asset generated thereon is not in use. These factual observations were not controverted by the revenue before us. - Order of CIT(A) confirmed - AT
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