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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Disallowance of deduction u/s 10B - The tribunal examined the appellant's claim regarding deductions under Section 10B for miscellaneous incomes like scrap sales and tool development income. It referred to judicial precedents and the Act's provisions, concluding that such incomes, being integral to the business operations of Export Oriented Units (EOUs), qualify for deduction under Section 10B. This interpretation aligns with the legislative intent to encourage exports by offering tax incentives for incomes directly related to the business activity of EOUs.
Disallowance of deduction u/s 10B - The tribunal examined the appellant's claim regarding deductions under Section 10B for miscellaneous incomes like scrap sales and tool development income. It referred to judicial precedents and the Act's provisions, concluding that such incomes, being integral to the business operations of Export Oriented Units (EOUs), qualify for deduction under Section 10B. This interpretation aligns with the legislative intent to encourage exports by offering tax incentives for incomes directly related to the business activity of EOUs.
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