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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Disallowing claim of expenditure - non-carrying of business activity during the year under reference - The case involved an appeal by an assessee against the disallowance of expenditure claimed during the assessment year due to the absence of revenue generation. The assessee, engaged in real estate business, argued that it had commenced its business by purchasing land, which was reflected in its balance sheet. The ITAT, relying on relevant precedent, concluded that the acquisition of land marked the initiation of business operations, irrespective of revenue generation during the assessment year. Consequently, the Tribunal allowed the appeal, affirming the allowability of the claimed expenditure.
Disallowing claim of expenditure - non-carrying of business activity during the year under reference - The case involved an appeal by an assessee against the disallowance of expenditure claimed during the assessment year due to the absence of revenue generation. The assessee, engaged in real estate business, argued that it had commenced its business by purchasing land, which was reflected in its balance sheet. The ITAT, relying on relevant precedent, concluded that the acquisition of land marked the initiation of business operations, irrespective of revenue generation during the assessment year. Consequently, the Tribunal allowed the appeal, affirming the allowability of the claimed expenditure.
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