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 u/s 35(1)(ii) - withdrawal of approval by the CBDT as was granted to the said HHBRF was only on 06.09.2016 i.e. much after the donation made by the assessee. Principally, even if subsequently for any reason if approval granted is withdrawn the deduction claimed cannot be denied. We, thus, are of the considered opinion that the disallowance made under Section 35(1)(ii) of the Act is not sustainable in the eye of law and hence quashed - AT
Disallowance u/s 35(1)(ii) - withdrawal of approval by the CBDT as was granted to the said HHBRF was only on 06.09.2016 i.e. much after the donation made by the assessee. Principally, even if subsequently for any reason if approval granted is withdrawn the deduction claimed cannot be denied. We, thus, are of the considered opinion that the disallowance made under Section 35(1)(ii) of the Act is not sustainable in the eye of law and hence quashed - AT
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