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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Addition u/s 14A r.w.r. 8D - Addition under special provision u/s 115JB - Minimum Alternate Tax (MAT) - the case revolved around the disallowance made under Section 14A of the Income Tax Act and its implications for computing Minimum Alternate Tax (MAT) under Section 115JB. The Court upheld the ITAT's decision to delete the disallowance under Section 14A and concluded that such disallowance cannot be added back to book profit for MAT computation under Section 115JB.
Addition u/s 14A r.w.r. 8D - Addition under special provision u/s 115JB - Minimum Alternate Tax (MAT) - the case revolved around the disallowance made under Section 14A of the Income Tax Act and its implications for computing Minimum Alternate Tax (MAT) under Section 115JB. The Court upheld the ITAT's decision to delete the disallowance under Section 14A and concluded that such disallowance cannot be added back to book profit for MAT computation under Section 115JB.
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