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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Weighted deductions claimed u/s 35(2AB) - The petitioner challenged the restriction of the eligibility period for weighted deductions on R&D expenditure, contending it should cover all expenditures since 01 April 2018, not just from 27 February 2019. - The High Court held that the restriction was untenable and against the legislative intent of Section 35(2AB), which aims to encourage R&D by allowing deductions for related expenditures without linking them to the date of DSIR approval. - The Court clarified that the eligibility for deductions under Section 35(2AB) is not limited to expenditures incurred post the DSIR's approval of the R&D facility.
Weighted deductions claimed u/s 35(2AB) - The petitioner challenged the restriction of the eligibility period for weighted deductions on R&D expenditure, contending it should cover all expenditures since 01 April 2018, not just from 27 February 2019. - The High Court held that the restriction was untenable and against the legislative intent of Section 35(2AB), which aims to encourage R&D by allowing deductions for related expenditures without linking them to the date of DSIR approval. - The Court clarified that the eligibility for deductions under Section 35(2AB) is not limited to expenditures incurred post the DSIR's approval of the R&D facility.
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