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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Depreciation on foreign exchange fluctuation loss - foreign currency term loan availed for purchase of windmill - since the assessee has capitalized and claimed depreciation in spread over years and assessments have become final and in this year, the assessee has made claim of depreciation @ 80% on the loan on account of foreign exchange fluctuation loss relating to foreign currency term loan, which was availed for the purchase of this windmill and capitalized, hence we are of the view that the assessee is entitled for claim of depreciation and we allow the same. - AT
Depreciation on foreign exchange fluctuation loss - foreign currency term loan availed for purchase of windmill - since the assessee has capitalized and claimed depreciation in spread over years and assessments have become final and in this year, the assessee has made claim of depreciation @ 80% on the loan on account of foreign exchange fluctuation loss relating to foreign currency term loan, which was availed for the purchase of this windmill and capitalized, hence we are of the view that the assessee is entitled for claim of depreciation and we allow the same. - AT
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