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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Rectification proceedings u/s. 154 - Unexplained investment addition u/s 69 - The case involved the treatment of surrendered undisclosed income under the head of Business Income versus taxation u/s 115BBE of the Income Tax Act. The appellant argued against the rectification notice issued to tax the surrendered income u/s 115BBE, contending that it should be taxed as business income. The Tribunal, citing precedent cases, ruled in favor of the appellant, stating that if the surrendered income is related to regular business activities, it should be taxed as business income. Therefore, the order passed u/s 154 to tax the income u/s 115BBE was quashed, and the appeal was allowed.
Rectification proceedings u/s. 154 - Unexplained investment addition u/s 69 - The case involved the treatment of surrendered undisclosed income under the head of Business Income versus taxation u/s 115BBE of the Income Tax Act. The appellant argued against the rectification notice issued to tax the surrendered income u/s 115BBE, contending that it should be taxed as business income. The Tribunal, citing precedent cases, ruled in favor of the appellant, stating that if the surrendered income is related to regular business activities, it should be taxed as business income. Therefore, the order passed u/s 154 to tax the income u/s 115BBE was quashed, and the appeal was allowed.
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