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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Correct head of income - addition of interest income on margin money kept with Bank/Financial Institution taxable under the head ‘income from other sources’ - The ITAT held that, the fact that interest has been earned and the margin money was kept for purpose of guarantees and letter of credit in relation to setting up of the project has not been disputed, thus, same being linked inextricably with setting up of the plant, interest is eligible for deduction against the cost of the asset or capital work-in-progress.
Correct head of income - addition of interest income on margin money kept with Bank/Financial Institution taxable under the head ‘income from other sources’ - The ITAT held that, the fact that interest has been earned and the margin money was kept for purpose of guarantees and letter of credit in relation to setting up of the project has not been disputed, thus, same being linked inextricably with setting up of the plant, interest is eligible for deduction against the cost of the asset or capital work-in-progress.
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