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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Bad Debts - Loans advanced to the Group Company utilized for purchase of properties and shares - The High court holds that it's not necessary for the assessee to establish that the debt went bad during the relevant previous year. If the assessee can demonstrate a bona fide belief that the debt had become bad and is written off accordingly, the claim should be allowed. - The High court concurs with the ITAT's finding that the nature and quality of the transaction, not just how it's recorded in the books, are crucial in determining its character. The fact that the transaction was recorded as a loan in the books does not negate its potential qualification as a bad debt.
Bad Debts - Loans advanced to the Group Company utilized for purchase of properties and shares - The High court holds that it's not necessary for the assessee to establish that the debt went bad during the relevant previous year. If the assessee can demonstrate a bona fide belief that the debt had become bad and is written off accordingly, the claim should be allowed. - The High court concurs with the ITAT's finding that the nature and quality of the transaction, not just how it's recorded in the books, are crucial in determining its character. The fact that the transaction was recorded as a loan in the books does not negate its potential qualification as a bad debt.
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